The concept of a principal company structure (PCS) is far from new, yet national tax regimes are increasingly targeting these structures for enhanced and aggressive scrutiny. While this increased scrutiny is not limited to Swiss-based PCSs, Carl Bellingham and John Lindstrom of PwC warn that tax authorities may focus on a Swiss-based PCS due to the sheer number of such structures in Switzerland.
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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