Italian taxpayers could receive significant benefits if they enter into the tax authority’s cooperative compliance relationship. These could include removing the need for preventive rulings to enable them to deal with entities in blacklisted jurisdictions, less data reporting requirements around transactions and a removal of the requirement to provide bank guarantees in relation to tax credits.
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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