In the wake of a recent Supreme Court ruling, the reasonable taxation standard is clarified, and activities within the scope of the Irish IFSC regime are found to be
comparable to activities within the scope of the Dutch GFC regime. By Daan de Bruin and Judy Chan Deloitte & Touche, International Tax Group, Netherlands
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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
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