Eastern Value Partners (Eastern Value), a subsidiary of Cyprus-based private equity group Exelor, with a permanent establishment in Russia, is entitled to tax benefits under the Russia-Cyprus double tax treaty (DTT) despite the tax authority’s claims it was treaty shopping, Russia’s Ninth Arbitration Court of Appeal has ruled.
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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