This is going to be fun.
For example, what's a low or no tax jurisdiction? The UK is going to create a tax haven list at last. Listen to the howls arising from St Helier, St Peter Port and Douglas, for a start.
And then note this will 'look through' intermediaries. Could 'Double Irish' and 'Dutch sandwiches' be in line for UK attention? That's going to be popular in Dublin and Amsterdam.
And in that case is this an admission that the Google or Diverted Profits Tax was an over complicated tool for something that could be done a lot more simply? Especially when, I note, the phrase 'apply this to to all payments connected with the activities of a business liable for tax in the UK'. Could this just be a statement of intent to apply the withholding to payments made by sales agents even if they do not settler a royalty? If so, this will be fun.
And, as a final note, why has it taken so long for the tax justice movement to be listened to on withholding when we have suggested it for so long?
I awaiting the wails not just offshore but all the way back to the States on this one.