Boris Bruk and Evgeny Timofeev of Salans in Russia analyse the Bloomberg case and discover that the ruling will inspire further discussions about the framework of preparatory and auxiliary activities within the scope of the permanent establishment concept
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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