The Google Tax – Some (Very) Initial Thoughts by Tax Barrister Jolyon Maugham

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Dec 152014
 

The following is a guest article written by tax barrister Jolyon Maugham, who also writes for his own tax blog Waiting for Godot. These are Jolyon’s views on the new Diverted Profits Tax (“DPT”, or “Google Tax”) that was introduced in the recent Autumn Statement. Jolyon has kindly agreed to share his initial views on Tax Notes.

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Dec 032014
 

I am grateful to Alain Thielemans of International Tax Plaza for providing the following information about the new Consultation Paper on addressing mismatches in the tax treatment of hybrid instruments.

A hybrid is exactly that – a cross between two different creatures to produce a creature that has the qualities of both its parents. A typical example of a hybrid would be a debt security issued by a company that is convertible to equity at the option of one or both parties. You can read more about hybrids in the HMRC Manuals. Continue reading »