When Dave Hartnett, HMRC's permanent secretary for tax, told the Tax Planning Strategies meeting in Paris, organised by the IBA, the ABA, IFA and the OECD, that the UK is to lead a survey into the practicality of global transfer pricing guidelines, you could be sure that practitioners around the world would have an opinion.
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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