Her Majesty’s Revenue & Customs (HMRC) is expected to change the penalties it imposes on erroneous transfer pricing documentation from April. It is thought that the minimum penalty applied will be 10% of the total tax lost to HMRC although the total penalty will depend on the severity of the error.
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Valid pillar two objectives are still intact after the side-by-side agreement, but whether the framework is now settled is ‘a $64,000 question’, Morrison Foerster’s tax chair told ITR
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