The Finance (No 3) Bill 2018 was published on 7 November 2018. The second reading of the Bill in Parliament took place on 12 November 2018. When it has completed its passage through Parliament the Bill will become the Finance Act 2019 .

The Bill contains measures already announced in the budget but with more detail on some of the provisions.

Diverted profits tax

The diverted profits tax (DPT) rules have been modified to address potential tax planning opportunities arising from the interaction between transfer pricing rules and the calculation of diverted profits. Also the end of the charging notice review period will be extended to 15 months after the relevant DPT charge due date.

International tax disclosure and information exchange

The Bill contains enabling legislation allowing the UK government to implement amendments to the EU Directive on mandatory automatic exchange of information. This provision would allow the introduction of the EU Mandatory Disclosure (DAC6) rules via secondary legislation during 2019. The provision gives the government scope to implement OECD recommendations on mandatory disclosure rules for common reporting standard avoidance arrangements and in relation to opaque offshore structures.

Corporate capital gains

With effect from 1 January 2020 there will be a deemed market value base cost for capital gains tax in relation to intangible fixed assets that come within the UK charge to corporation tax as a result of a non-resident company becoming UK resident, or where the relevant asset begins to be used by a UK permanent establishment (PE), and an exit charge is applied in another EU jurisdiction.

Also, with effect from 6 April 2019 companies resident in another EEA member state that suffer deemed disposals because assets have ceased to be used in a UK PE will be able to enter into an exit charge payment plan and pay the tax due in six equal annual instalments.

Other

The Bill contains some new legislation on capital allowances, the taxation of intangibles and hybrid capital instruments as well as revised legislation to deal with the tax implications of IFRS 16 in relation to leasing.