Article 48 of the Federal Fiscal Code provides the procedure to be followed by the tax authorities where an audit or review takes place at the tax authority’s offices (not in the domicile of the taxpayer).
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap