With the BEPS project increasingly reining in countries’ ability to offer tax incentives, governments advocate a low corporate income tax rate as pivotal for attracting business. However, corporate stakeholders, economists and academics in the transfer pricing community point to the diminishing value of corporate income tax.
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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