On July 23 2004 the Italian central tax agency issued the explanatory notes (the Explanatory Notes) envisaged by article 8(2) of Law Decree 269, of September 30 2003 (Decree 269) necessary to allow certain enterprises that carry on an international activity (each an International Enterprise) to apply for the ad-hoc ruling procedure (the International Ruling Procedure) established by article 8 of same Decree 269
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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