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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A landmark ruling on LLP taxation has clarified who truly holds ‘significant influence’ and which partnership structures are most likely to withstand HMRC scrutiny
Fresh from the UN negotiations in New York, Alex Cobham offers ITR readers a rare first-hand perspective on the future of international tax cooperation
Despite initial hopes that the reporting obligation had been suspended, compliance challenges brought by Brazil’s indirect tax reform are very much a reality