Helga Marie Andresen and Merethe Bryn of Deloitte in Norway discuss the court’s ruling in the landmark case of ConocoPhillips, which shifted the tax authority’s approach to evaluating whether Norwegian companies receive their part of the profit compared to the group as a whole.
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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