BP Solar’s sale of a number of PV plants in Italy to a leading insurance company gave rise to a complex tax structuring case, which was also affected by a new interpretation by Italy’s tax authorities, explains Federico Trutalli of NCTM, who advised the seller during the transaction.
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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