Taxpayers in Asia face the twin challenges of increased scrutiny from jurisdictions with long-standing transfer pricing regimes and greater awareness of connected issues such as the interaction with customs, in contrast to those countries for whom transfer pricing enforcement is still new, explain Kari Pahlman, John Kondos and Alex Capri of KPMG
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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