Mismatches create opportunities. This is true in any scenario, whether it is the opportunity for a fleet-footed and nimble winger to gain an advantage by exposing the bulky, flat-footed front-row rugby forward who has temporarily become his opposite man, or whether it is in the (equally ruck-filled) field of tax planning. Matthew Gilleard looks at where the OECD is drawing the line when it comes to activity that takes advantage of tax law mismatches in an intended or acceptable manner, and that which is not.
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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