Taxpayers have made six proposals to the Canadian government to maintain the international competitiveness of the economy, including the elimination of withholding tax on intercompany dividends in the Canada-US tax treaty, the introduction of a participation exemption for foreign dividends and the establishment of a system that would allow for loss transfer or group loss relief
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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