Hutchison Whampoa recently won a bid for tax relief on losses by its UK mobile phone unit, Three, after the European Court of Justice (ECJ) found that Britain had violated EU anti-discrimination rules by blocking the transfer of the losses to group companies. The ruling has called into question the government’s ability to tax international groups under the control of third country parent companies.
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While it’s great that the OECD is alive to multinationals’ fears of being caught in a compliance trap, the ‘common understanding’ illustrates a worrying lack of readiness
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