Law360, New York ( February 11, 2015, 2:25 PM EST) -- The U.K. is proposing to introduce a unilateral anti-BEPS (base erosion and profit shifting) provision not coordinated by the Organization for Economic Cooperation and Development and referred to in the media as a "Google tax," with effect from April 1, 2015. The draft provision is very complex, and it will be time-consuming to assess its potential impact on many common cross-border business structures. The question of its applicability is heavily fact-based, so that even those unlikely to be affected may need to incur significant time and effort in reaching that conclusion....
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