Despite the Australian authorities promoting the separate entity approach during the OECD’s project on permanent establishments (PE), the Treasury now looks to be doing an about-turn in favour of the single entity approach, which advisers say is creating confusion and uncertainty amongst taxpayers.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
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