Are new laws incapable of being subject to statutory construction to depict their meaning? Or are such laws so poorly drafted that companies must glean their intended meaning, outside the parameters of the legislated verbiage, from conference reports, statements of intent by tax authorities at international conferences and referencing documents?
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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