Back in January, the European Commission launched a public consultation on the double non-taxation of cross-border companies. The Commission hopes the consultation will gauge the full scale of the problem and see where the main weaknesses lie and will develop a policy response before the end of 2012. Jack Grocott speaks to Philip Kermode, Director for Direct Taxation in DG Taxation and Customs, about what he hopes the consultation will achieve and what it means for taxpayers.
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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
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