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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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