The conclusion of a bilateral advance pricing agreement (APA) between the US and the Netherlands will allow FEI, a scientific instruments company, to release large valuation allowance and tax reserves from its accounts for the second quarter of 2010.
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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