The 2015 enhancements to China’s restructuring tax relief rules, the challenging new indirect offshore disposal rules in SAT Announcement 7, developments in financial instrument tax classification and the revamped tax treaty relief procedures are the focus of this article by KPMG’s John Gu, State Shi, Josephine Jiang, Chris Mak and Yvette Chan.
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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