In March 2010 HM Revenue & Customs (HMRC) released an update of the guidance in its International Manual on the UK’s thin capitalisation rules. This guidance is prepared primarily to assist inspectors of taxes in applying the thin cap legislation, but also offers useful insights into HMRC policy for taxpayers and advisers.
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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