Companies are advised to check for relevant changes to their respective domestic laws following the signing of the OECD’s multilateral instrument (MLI) by 76 countries with much fanfare on Wednesday. The rewriting of bilateral taxation treaties on such a large scale is expected to improve arbitration in tax dispute resolution and curb double taxation, but is likely to be implemented to varying degrees across jurisdictions.
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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