The UK Inland Revenue has acted to close what it sees as a loophole in tax law that allows companies involved in international mergers and acquisitions to avoid a 1.5% tax. A number of recent transactions, including the BP/Amoco merger, the Astra/Zeneca merger and the Vodafone/Airtouch deal, were structured to benefit from an exemption which allowed the companies to avoid the 1.5% stamp duty reserve tax.
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No further action will be taken in relation to the four cases, however the regulator said it hopes to conclude five remaining investigations into PwC’s tax leaks scandal ‘as soon as possible’
The OECD also reported ‘political issues’ in reaching a consensus on amount B; in other news, PwC introduced new managing director roles as a partnership alternative
Coca-Cola ‘strongly believes’ the IRS and the Tax Court misinterpreted and misapplied the applicable regulations for its TP dispute over foreign affiliates
The self-governing UK dependency said that over 95% of Jersey companies will be unaffected by pillar two and that Revenue Jersey is ‘well-equipped’ to implement the rules
Specialist technology can save companies time, money and compliance stress by revolutionising a multitude of TP processes, says Russell Gammon of Tax Systems