"The EU has drafted an anti-tax avoidance directive, for approval by the European Council. As the UK has been a driving force behind the OECD-G20 BEPS project, the UK is already ahead of the curve in implementing the various anti-avoidance rules, such as a general anti-abuse rule, CFC rules. However, anti-hybrid rules are in Finance Bill 2016, and there is a question mark now hanging over the Finance Bill, since it would need to obtain Royal Assent by mid-October if it is to be enacted. A big issue for multinationals is undoubtedly the question of corporate interest deductibility, (broadly) set to be capped at 30% of EBITDA, which is also in the draft EU directive. However, as this was driven by the OECD-G20, it is highly unlikely the UK will shy away from this now. "
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