The OECD has published a 42-page Country-by-Country Reporting Implementation Package this week, which consists of model legislation, a multilateral competent authority agreement on the exchange of country-by-country reports, two other competent authority agreements, one based on a double tax convention, the other based on a tax information exchange agreement (TIEA), and a confidentiality and data safeguards questionnaire.
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HMRC expects advisers to meet ever-higher compliance criteria. After 24 consecutive qualified audit opinions, many will ask whether HMRC should hold itself to the same standards
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