With the Secret Hotels2 Limited decision released on December 3 2012, the UK Court of Appeal has provided guidance on the correct approach to be taken when determining who is the supplier of a service in agency / principal arrangements, explain Mark Delaney and Arianne Wijdeveld of Baker & McKenzie.
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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