The digital revolution has transformed business models, entire economies and the lives of people around the globe. It has also tested the concept of traditional corporate tax rules, designed largely in the first half of the 20th century. These rules are now unfit for our increasingly digitalised and globalised world.
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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