Peter Nias, international tax specialist barrister at Pump Court Tax Chambers in London, analyses trends in international tax dispute resolution, looking at alternative dispute resolution methods and whether the OECD’s recent work in this area represents a missed opportunity.
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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