UK HMRC has launched a public consultation on the design of legislation for a new royalty withholding tax rule announced as part of the Autumn Budget 2017 ({News-2017-11-27/P/3-previous coverage}). The proposed rule will mean that payments for the exploitation of certain property or rights in the UK that are made to connected parties in low or no tax jurisdictions will be subject to appropriate taxation. The rule does not represent a change in the UK’s general approach to taxation of UK source payments, but is a targeted rule aimed at intra-group arrangements that achieve an artificially low effective rate that...