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The new anti-avoidance rules on profit fragmentation apply from April 2019.  They are designed to target abusive arrangements but the draft legislation is much wider.  We believe that many normal businesses may need to notify HMRC of arrangements involving overseas entities under the new rules, even if it is clear that no extra tax will ultimately be due.  We have brought this to HMRC’s attention but it is unlikely that any industry specific exemptions will be introduced.