Hello everyone, welcome to this next PWC Taxbyte on the Brexit.

My name is Peter Derey and I have brought with me today a few experts to talk with you about the Brexit.

We're not going to talk about VAT, flow of goods, people, all of these are very, very important

topics, probably very high on your agenda if you talk about or think about the impact of Brexit,

but today we will talk about the direct tax consequences, probably less high on the agenda,

but nevertheless, as we will be discussing today, it is something you need to consider.

So who do I have with me today?

We have Jenny Bullivan, an international tax expert based in the UK.

So we will get the UK insights in this podcast as well.

And we have Tamara Goose and Jean-Philippe van West, two international

tax experts in my team here in Brussels. Together, we will talk about the Brexit impact and direct

taxes. I'm very curious, Jenny. Can you share a bit of your thoughts on what are according

to you, the main direct tax consequences of the Brexit?

Thanks, Peter. Yeah, as you've said, direct tax is not really the headline at Brexit,

and that's probably why this isn't the first in your Brexit series. There are some important changes,

though, impacting direct taxation. And I've

split these between those that have an obvious impact and those where the impact is less

obvious. So I think most of the listeners will know that after the 1st of January 2021, the EU directives will no longer be applicable to UK companies,

that be the parent subsidiary directive, the interest in royalties directive, etc.

I thought I'd give an example of how that might affect you.

So you may currently have a clearance in place

under, for example, the interest and royalties directive. Now, the UK tax authorities have said

...