The intricacies of the Russian audit and dispute resolution procedures are often challenging for taxpayers but some advisers believe both the system and officials are becoming more amenable. Recent advance pricing agreements (APAs) with oil companies Rosneft and Gazpromneft show a more collaborative approach in action.
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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