Deloitte & Touche has recruited John Lyons, formerly a top executive at the Internal Revenue Service (IRS), as global director of its Competent Authority Practice based in Washington. One of Lyons' principal responsibilities is to expand the Competent Authority Practice by recruiting tax treaty and transfer pricing professionals around the world.
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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