The European Court of Justice’s (ECJ) decision to disallow the Belgian tax authorities’ attempt to turn exempt capital gains into taxable profits in the Gimle case gives taxpayers certainty on the accounting treatment of acquisitions and removes the need to undertake contrived intra-group transactions to obtain an exemption.
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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