Substantial changes have been made to the profit fragmentation anti-avoidance since the original consultation was published, writes Mark Saunders (PwC).
The draft provisions contain a number of measures related to enforcement and HMRC powers. Jason Collins (Pinsent Masons) takes a look.
The proposed new regime will not be as straightforward to apply in practice as HMRC suggests, writes Andrew Parkes (Milestone International Tax Partners).