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

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Presenter Andrew Seidler Partner, RSM UK andrew.seidler@rsmuk.com +44 20 3201 8615 • International Tax Partner, RSM London • 20 years international tax experience across range of taxes • Chair of RSM International European Tax Centre of Excellence • Author of Tolley’s International Tax Planning 2017-18 and 2018-19 (forthcoming). 2
Overview BEPS Global Tax Reform US Tax Reform BREXIT 3
Page 1: Helping with tax challenges whereve
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 and 24: US Hybrid Counteraction The Act den
Page 25 and 26: UK approach compared to US Type Mis
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

2. Int&#039;l Tax Update Significant Developments in the Global Tax System - Andrew Seidler

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