Jurisdictions are beginning to create ‘synthesised texts’ to help taxpayers understand how the OECD’s multilateral instrument (MLI) interacts with bilateral double tax treaties, but some believe they do not offer the legal clarity taxpayers seek and risk future disputes.
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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