Following the European Court of Justice's judgment in ICI v Colmer, the UK Inland Revenue has said that claims for group and consortium relief will now be accepted between UK-resident companies where a group or consortium is established by reference to companies resident in the European Union (EU) or the European Economic Area (EEA).
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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