France’s thin capitalisation rules are being drastically amended at the end of year in the 2011 Finance Act. Laurent Borey and Antoine Belgrand, of Mayer Brown argue that taxpayers need to pay close attention to these changes or face problems down the line.
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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