As the UK High Court is about to give details of its referral of a thin-capitalization group litigation order to the European Court of Justice (ECJ), Philip Martin, formerly deputy head of tax at retailer Marks & Spencer, has abruptly left Dorsey & Whitney, the US law firm handling the order for claimants including Pepsi, Volvo and a subsidiary of Caterpillar
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Ireland’s Department of Finance reported increased income tax, VAT and corporation tax receipts from 2024; in other news, it’s understood that HSBC has agreed to pay the French treasury to settle a tax investigation
The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two