A challenge by the Portuguese tax authorities of a multinational’s cash pooling arrangement – because the authorities felt it inappropriately used the comparable uncontrolled price (CUP) – has been denied by an arbitration court. The case should alert Portuguese taxpayers to review the arm’s-length nature of their cash pooling arrangements.
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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