Michael Danilack, Deputy Commissioner of the Large Business and International Division (LB&I) at the Internal Revenue Service (IRS), announced yesterday during Tax Council Policy Institute’s (TCPI) conference in Washington DC that a new transfer pricing director will be appointed to LB&I within days.
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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