Event highlights European business restructuring challenges
February 10, 2009
Taxpayers were warned of the UK government’s dual approach to disregarding transactions at a transfer pricing conference in New York last week.
Advisers said that HM Revenue & Customs officials first ask whether there is a legal basis upon which the restructuring can be treated as having never occurred and then even if, legally, the restructuring did occur, whether the local tax authority can find a way to tax the transaction and the continuing operations of the company as if it had not occurred.
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