Vietnam’s changing trade patterns have resulted in a deficit that the government is now seeking to plug by expanding its tax base. Reforms on interest loans with related or third parties have already come into effect and further changes to thin-capitalisation rules are expected for multinationals.
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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