UK HMRC has launched a public consultation on proposals to address tax avoidance involving profit fragmentation. In particular, the consultation seeks views to inform detailed policy design principles for new legislation to tackle arrangements entered into by individuals, partnerships, or companies that aim to place profits proper to the UK outside the scope of UK taxation, often through the use of offshore trusts and companies. The focus of the new legislation will be on avoidance arrangements entered into by SMEs, which have generally been excluded from measures that target larger companies, such as the Diverted Profits Tax and the Hybrid...