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The Court of Appeal ruling clarifies that treaty benefits are not abusive where transactions are commercially driven, providing greater certainty on “main purpose” anti-avoidance tests
The repeal of Libya’s statute of limitations and tougher enforcement leave taxpayers navigating a high-stakes choice between conciliation and litigation
A revised Chapter VII signals a move away from mechanical TP approaches, stressing transaction understanding, functional analysis and context-driven documentation requirements
HMRC’s growing focus on evidencing tax decisions is shifting attention from technical accuracy to governance, requiring businesses to demonstrate how positions were reached and documented
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