RoadMap

RoadMap includes at least two proposals, which contain the measures to combat tax evasion, namely, methods for solving hybrid mismatch arrangements and measures that limit the deductibility of corporate interest. In addition, RoadMap includes specific changes to enhance tax regime for royalty payments.

RoadMap states that the government will present in April 2017, a fixed rule limiting the deductibility of interest for the largest companies, to 30 percent of UK income.

Next, RoadMap includes plans for the elimination of tax benefits arising from the use of hybrid mismatch arrangements involving permanent establishments (PEs). This measure is aimed at complex structures that allow some multinational corporations to avoid paying any taxes.

Finally, RoadMap states that the government will seek to expand the tax lien so that the payments for the use of intangible assets such as trademarks, trade names, made to overseas persons will be subject to withholding tax.

Chancellor George Osborne said that the RoadMap "establish a low tax regime which will attract multinational companies that we want to see in the UK, but we want to make sure that the taxes they pay here. This will be reflected in a positive way for our small firms. This approach we take following the best practices set out by the Organisation for Economic Co-operation and Development. "

Author: Olena Kutova

senior lawyer of the Finance Business Service company