On November 5 the US-based International Consortium of Investigate Journalists (ICIJ) released the tax rulings of 548 corporations accused of having ‘secret tax agreements’ with Luxembourg. A follow-up piece in the Australian Financial Review went as far as to accuse the Big 4 of facilitating the agreements in an article titled ‘Big four audit firms behind global profit shifting’.
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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