With the release of the OECD’s final package of recommendations to tackle base erosion and profit shifting (BEPS), the focus now shifts to the manner in which national authorities take up, and implement, the measures outlined. Country-by-country reporting (CbCR) implementation has already begun in a number of countries, including Germany, and use of the reporting method is set to be expanded next year.
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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