Erica Gut and David Balaban of PwC analyse the International Swaps and Derivatives Association's (ISDA) recently released protocol to deal with a provision in FATCA that could subject derivative transactions to a 30% withholding tax on certain US-sourced payments.
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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