2. Int'l Tax Update Significant Developments in the Global Tax System - Andrew Seidler

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UK approach Type Mismatch involving Primary Response Defensive Rule Scope D/NI Ch 3: Financial Instruments Deny payer deduction Related parties and structured Include as ordinary income arrangements D/NI Ch 4: Hybrid Transfers Deny payer deduction Related parties and structured Include as ordinary income arrangements D/NI Ch 5: Hybrid Payer Deny payer deduction Control group and structured Include as ordinary income arrangements D/NI Ch 6 Transfers by Permanent Establishments Deny deduction to UK PE No limitation on response D/NI Ch 7: Hybrid Payee Deny payer deduction Include as ordinary income Control group and structured in investor, then LLP arrangements D/NI Ch 8: Multinational Payee Deny payer deduction Control group and structured arrangements DD Ch 9: Hybrid Entity Deny investor deduction Deny payer deduction Related parties and structured arrangements Dual resident company deny deduction DD D/NI Ch 10: Dual Territory Multinational company: deny parent jurisdiction deduction Ch 11: Imported Mismatches Deny payer deduction Tolley’s International Tax Planning 2017/18 Multinational company: deny deduction to UK PE No limitation on response Control group and structured arrangements
UK approach compared to US Type Mismatch involving Primary Response D/NI Ch 3: Financial Instruments Deny payer deduction D/NI Ch 4: Hybrid Transfers Deny payer deduction D/NI Ch 5: Hybrid Payer Deny payer deduction D/NI Ch 6 Transfers by Permanent Deny deduction to UK PE Establishments D/NI Ch 7: Hybrid Payee Deny payer deduction D/NI Ch 8: Multinational Payee Deny payer deduction DD Ch 9: Hybrid Entity Deny investor deduction Dual resident company deny deduction DD D/NI Ch 10: Dual Territory Ch 11: Imported Mismatches Multinational company: deny parent jurisdiction deduction Deny payer deduction US hybrid entity Acquisition US UK Holdco Non-US Affiliate UK Not a US hybrid transaction? Interest Interest group relief Who has to disallow first?
Page 1 and 2: Helping with tax challenges whereve
Page 3 and 4: Overview BEPS Global Tax Reform US
Page 5 and 6: Corporate changes Tax change Post r
Page 7 and 8: Corporate changes Tax change Post r
Page 9 and 10: UK Planning Considerations: NOL Lim
Page 11 and 12: Withholding Taxes After Brexit •
Page 13 and 14: Withholding Taxes and the Digital E
Page 15 and 16: Common Consolidated Corporate Tax B
Page 17 and 18: Digital Economy Interim Measure Exa
Page 19 and 20: BEPS Measures: Anti-hybrid rules In
Page 21 and 22: Anti-hybrid provisions
Page 23: US Hybrid Counteraction The Act den
Page 27 and 28: Interest Limitation
Page 29 and 30: Interest deduction - comparison wit
Page 31 and 32: Global Intangible Low Taxed Income
Page 33 and 34: GILTI Example Calculation GILTI Cal
Page 35 and 36: Foreign Derived Intangible Income F
Page 37 and 38: FDII Example US Corp US sales $500
Page 39 and 40: FDII Example Step 4: Determine Rati
Page 41 and 42: UK Planning Considerations: FDII Pu
Page 43 and 44: BEAT - Base Erosion Anti-Abuse Tax
Page 45 and 46: UK Planning Considerations: BEAT In
Page 47 and 48: Brexit Monitor Visit https://www.rs
Page 49: THANK YOU

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2. Int'l Tax Update Significant Developments in the Global Tax System - Andrew Seidler