Last, do I welcome it? Not unambiguously, no. First, this is heavily targeted and as Luxleaks shows abuse is much wider than this. This is a useful move, maybe, but very narrow in its focus. The omission of financing arrangements looks serious to me, and undermines much of the effectiveness if my interpretation that this is the case is correct. And a host of other problems, such as transfer mispricing are untouched, where an absence of resources is the issue. Which brings me to a key issue, which is whether HMRC will even have the capacity to enforce such a tax. But perhaps, most of all, I have reservations on the impact on the BEPS process. I will be preparing a separate blog on that for Economia magazine, which I will link to soon. - See more at: http://www.taxresearch.org.uk/Blog/2014/12/10/the-diverted-profits-tax-first-thoughts/#sthash.CQytgFow.dpuf