Since APAs became an option for corporate taxpayers, there has been a gradual shift in their purpose and a split in taxpayer and government approaches to the agreements. Catherine Snowdon discovers how the process of getting an APA needs to develop to better suit modern business.
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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