Franchising may be an appropriate framework for analysing intra-group transactions, including potentially in industries where third-party franchising is generally not observed, believe Emmanuel Llinares of NERA Economic Consulting in Paris and Nihan Mert-Beydilli of NERA Economic Consulting in Chicago
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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