Whether the government has taken sufficient action to ensure that multinational digital businesses pay their fair share of tax in the UK is a matter of intense public debate. The diverted profits tax, introduced in April 2015, surprised many by indicating parliament’s willingness to take unilateral action above and beyond the general OECD/Base Erosion and Profit Shifting (BEPS) consensus.

Perhaps emboldened by such unilateral measures, yet more threats of unilateral action directed at digital businesses were announced at November Budget 2017. The headline measure is the introduction, from April 2019, of a withholding tax on UK-sales-related royalties paid to low tax jurisdictions.