As the UK High Court is about to give details of its referral of a thin-capitalization group litigation order to the European Court of Justice (ECJ), Philip Martin, formerly deputy head of tax at retailer Marks & Spencer, has abruptly left Dorsey & Whitney, the US law firm handling the order for claimants including Pepsi, Volvo and a subsidiary of Caterpillar
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Despite the relief, Brazil’s government has also presented a bill which seeks to re-impose a tax burden on companies’ payroll, one local tax specialist told ITR
While successful pillar two implementation will require collaboration across all units, a combination of internal and external tax advice is at the centre of the effort