A Swedish court has ruled on timelines for information used in benchmarking searches in a case involving The Absolut Company, which produces Absolut Vodka. The court concluded, supported by the OECD Transfer Pricing Guidelines, that looking at data from years after the year under review would constitute hindsight and would not be accepted.
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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