BP Solar’s sale of a number of PV plants in Italy to a leading insurance company gave rise to a complex tax structuring case, which was also affected by a new interpretation by Italy’s tax authorities, explains Federico Trutalli of NCTM, who advised the seller during the transaction.
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The controversial deal would ‘preserve the gains achieved under pillar two’, the OECD said; in other news, HMRC outlined its approach to dealing with ‘harmful’ tax advisers
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