The Supreme Federal Court (STF) of Brazil resumed its judgment in the case set to decide the constitutionality of the country’s controlled foreign company (CFC) rules yesterday and confirmed an injunction meaning mining multinational Vale will not have to pay its R30.55 billion ($15.09 billion) tax assessment until the court has made further analysis.
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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