Hutchison Whampoa recently won a bid for tax relief on losses by its UK mobile phone unit, Three, after the European Court of Justice (ECJ) found that Britain had violated EU anti-discrimination rules by blocking the transfer of the losses to group companies. The ruling has called into question the government’s ability to tax international groups under the control of third country parent companies.
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Despite the relief, Brazil’s government has also presented a bill which seeks to re-impose a tax burden on companies’ payroll, one local tax specialist told ITR
While successful pillar two implementation will require collaboration across all units, a combination of internal and external tax advice is at the centre of the effort