A Plain English Guide to the UK Diverted Profits Tax
Channel: MyTPAGlobal
Date: 2015-04-26

A guide to assessing how the new UK Diverted Profit Tax, effective 1 April 2015, will apply to your UK and international operations and your UK reporting obligations.

The UK’s Diverted Profit Tax (DPT) or ’Google Tax’ as often dubbed by the British media, is a new tax effective 1 April 2015, introduced by the Chancellor as part of Finance (No.2) Bill 2015. The new charge (levied at 25%) is purported to be aimed at tackling aggressive international tax planning techniques used by large multinational corporations, in response to the view that the rafts of existing UK tax legislation do not go far enough in protecting the UK’s tax base. However, the reality is such that the rules are likely to have far wider application.  

TPA Global, together with Milestone International Tax Partners LLP, will provide you with a high level overview of the new rules and use common multinational case-studies to show you just how extensively the new rules are likely to apply.
The webinar will consider the following:

- Elaborate on the two key charging provisions of the UK DPT;
- Application of the “80% payment test;
- The “Insufficient Economic Substance Condition”;
- The reporting obligations under DPT (even if it is likely that no DPT charge would arise); and
- How the DPT may be calculated.

At the end of the webinar, you will:

- Understand the concept underlying the UK diverted profit tax;
- Be able to make an initial assessment as to whether your UK activities have a risk of falling within scope of the UK diverted profit tax regulations;
- Understand your notification and reporting obligations; and
- Be clear of the timeframe within which you have to take action.

Speakers

* Steef Huibregtse, CEO and Managing Partner, Transfer Pricing Associates
Steef Huibregtse is the founding member and managing partner of Transfer Pricing Associates. He has more than 25 years of experience in the area of international tax and transfer pricing consulting, and has been a leading transfer pricing partner with a wide reputation in the area of transfer pricing strategy, risk management, design, documentation and implementation services. His expertise covers more than 50 countries and a wide variety of industry, including telecommunications, automotive, fast moving consumer goods, financial services, pulp & paper, pharma and biotech, medical devices, oil & gas, publishing, retail and licensing. Steef’s proven track record includes the development of Global Transfer Pricing Control Framework Toolbox, involvement in more than 2,000 regional and global transfer pricing studies, development of a Global Benchmark Platform, and development of a global portal for intangibles.
     
* Zoe Wyatt, Director, Milestone International Tax Partners
Zoe Wyatt is now a Director at Milestone having come full circle since start her career there in 2006. After an in-house role at Acer, she moved to Grant Thornton where she was promoted to Associate Director and earned the role of Head of Tax for the China Britain Services Group.
As a Director at Milestone, she brings extensive knowledge of international systems with a special interest in double tax treaties, exploitation of IP and the role of EU law. Winner of Taxation’s ‘Rising Star’ award in 2011, Zoe has particular expertise in UK-Chinese bilateral investment and the energy and technology sectors.

* Igor Peters, Partner, Transfer Pricing Associates
Igor Peters is partner at Transfer Pricing Associates and has more than 19 years of experience in international taxation and transfer pricing. His previous experience includes 8 years as in-house tax counsel in Germany and the Netherlands with focus on transfer pricing and tax risk management. Igor worked on (business restructuring) projects both as tax consultant and as in-house tax counsel with in-house experience with project oriented and supply-chain structured companies. As in-house tax counsel he worked in a wide variety of industries, including heavy machinery, oil and gas engineering & construction, consumer electronics. In his current role he provides transfer pricing advice and assistance to multinationals of all sizes, wherever they are located, with a strong focus on the design of transfer pricing systems.