Commentary

D2.806 Digital services tax—anti-avoidance

Corporate tax
Corporate tax | Commentary

D2.806 Digital services tax—anti-avoidance

Corporate tax | Commentary

D2.806 Digital services tax—anti-avoidance

A targeted anti-avoidance measure for digital services tax (DST) is included in the provisions and drafted similarly to other anti-avoidance measures, for example in the anti-hybrid provisions of TIOPA 2010. Any arrangement entered into by a taxpayer with a main purpose of obtaining a tax advantage may be counteracted by a just and reasonable adjustment1. Tax is specifically defined as DST here. The drafting is intentionally broad and allows any such adjustment to be made to give a just and reasonable outcome, including assessments or otherwise, by HMRC or the taxpayer. One exception to any anti-avoidance application

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