Much time and attention has been devoted to planning for a post-BEPS world, from analysing systems that may need to be adopted to looking at how taxpayer-tax authority relationships are likely to change. But less has been said about the impact of BEPS deliverables on commercial contract documentation and the extent to which such contracts will be scrutinised. Jen Winterhalder, a solicitor in PwC Legal and Latika Sharma, a partner and head of PwC Legal’s intellectual property and commercial contracts team, focus on the importance of matching contract terms to commercial substance, both now and for the future.
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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