Hong Kong’s highest court is deciding whether unrealised gains should be treated as profits for tax purposes after hearing the arguments in the Nice Cheer Investment case. The Court of Final Appeal’s (CFA) decision should finally settle the distinction to be drawn between legal principles and ordinary commercial accounting principles.
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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