Timothy Lyons QC and Kelly Stricklin-Coutinho of 39 Essex Chambers analyse recent transparency developments across Europe, focusing on the proposed requirement for EU member states to provide a quarterly report on all cross-border tax rulings and advance pricing arrangements.
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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