Today the German Upper House adopted the Act for Implementation of the Directive on the EU Recovery of Tax Claims which includes the amendment of the German anti-treaty/directive shopping rule set forth in Sec. 50d (3) of the German Income Tax Act (ITA).
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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