The CCCTB concept of relies on formulary apportionment, doing away with the arm’s-length principle (ALP). While many people welcome the opportunity to debate the future of tax compliance, others feel a switch to formulary apportionment will create just as many problems as the ALP. Sophie Ashley talks to the CCCTB’s critics and supporters about its impact on transfer pricing.
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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