The UK’s action in enacting the DPT ahead of the consensus outcome of BEPS action 7 may encourage other BEPS countries to do something similar. Indeed, Australia is reported to be interested in implementing a similar levy. It is not clear that such other DPTs would be (unilaterally) creditable against UK corporation tax, particularly if they too are considered not to be ‘substantially similar’ subsequently enacted taxes to the other country’s corporation tax.