Group structuring in 2015 and beyond

Five main tax factors are likely to prompt changes to group structures over the next few years: publicity and country by country reporting; BEPS-related tax treaty changes; action against hybrid mismatches; diverted profits tax (DPT); and state aid challenges. The priority for many in early 2015 will be to grapple with the DPT position, and to prepare for the imminent introduction of country by country reporting.