2017 brings significant challenges for big business with the commencement of the anti-hybrids rules, a new corporate interest restriction and changes to the carried-forward loss regime. Tax rulings will face increased scrutiny as the European Commission pursues its State aid challenges and automatic exchange of information on cross-border tax rulings commences. On the plus side, there will be improvements to the substantial shareholding exemption and the reduction in the rate of corporation tax to 19%.
This article was first published in the 13 January 2017 edition of Tax Journal
