In order to make this workable, the government would assume that certain industries make certain profit margins
e.g. 8% assumed profit for the sale of goods to 32% assumed profit for the sale of services. [0][1]
According to the FT:
"the new tax would be a “deemed profits” tax rather than a corporation tax, so as to sidestep issues about double tax treaties.
[...] the Treasury would identify profits that escaped tax in the UK because of royalty arrangements or the absence of a taxable presence.
[...] It seems to be something completely novel . . . It is a huge stick that will stop this artificial avoidance. The difficulty will be how it is defined in practice.” [2]
[0] Similar way to the way the UK flat rate VAT scheme works
According to the FT:
"the new tax would be a “deemed profits” tax rather than a corporation tax, so as to sidestep issues about double tax treaties.
[...] the Treasury would identify profits that escaped tax in the UK because of royalty arrangements or the absence of a taxable presence.
[...] It seems to be something completely novel . . . It is a huge stick that will stop this artificial avoidance. The difficulty will be how it is defined in practice.” [2]
[0] Similar way to the way the UK flat rate VAT scheme works
[1]http://www.internationallawoffice.com/newsletters/Detail.asp...
[2] http://www.ft.com/cms/s/0/127010ea-7af9-11e4-b630-00144feabd...