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<p>The UK initiated the G20/OECD Base Erosion and Profit Shifting project and has
already taken action to implement two of the internationally agreed outputs with domestic
legislation to introduce country-by-reporting and rules to address hybrid mismatches.</p><p>In
addition, the UK played a key role in securing the successful EU agreement on automatically
exchanging information on tax rulings, reached at the ECOFIN Council in October 2015.</p><p>Complementary
to international efforts to tackle this issue, we introduced the Diverted Profits
Tax from April 2015 to counteract the diversion of profits from the UK by large multinational
enterprises.</p><p>In the summer Budget 2015 we legislated to improve the effectiveness
of our Controlled Foreign Company (CFC) regime by removing the ability for companies
to use UK losses and reliefs against their CFC charge.</p>
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