The way in which multinationals avoid paying UK tax on profit generated by their UK operations is to use royalty structures in which UK business are required to pay a commercially acceptable royalty for the use of trade name and the brand. If there is to be a stop to profit shifting out of the UK, then these tax acceptable deductions will need to be reviewed to prevent profit flow. It will be interesting to see whether certain royalty structures will now be considered as falling with GAAR.