After years of debate, delay and controversy, the US has signed its double tax treaty with Venezuela. It is the first between the US and a Latin American country outside of NAFTA members. The treaty breaks new ground as Venezuela, like many other Latin American jurisdictions, has a territorial tax system. The hope is that the precedent set will be followed throughout the region.
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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