The EU’s Joint Transfer Pricing Forum (JTPF) has published a report on compensating adjustments, designed to bring more guidance for taxpayers, particularly those operating in European member states. But members of the forum, including taxpayers and advisers, have said the positions held by some member states have prevented the forum from providing a workable solution.
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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