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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The ruling underscores that tax authorities must provide ‘detailed, well-supported, and logically sound justifications’ when determining reference prices in tax assessments, one expert told ITR
One expert last month predicted the short-term impact of tariffs would be “devastating” for both Canada and the US, particularly if the former instituted retaliatory measures
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The court emphasised that TP analysis must adhere to the arm's-length principle, be based on the specific facts of each transaction and comply with domestic regulations, one expert says