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Glencore: MAPping unchartered territory

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The recent FTT decision granting two Glencore entities a stay of their diverted profits tax and corporation tax appeal proceedings offers important insights into the interaction between domestic appeals and the mutual agreement procedures provided for in double tax treaties. HMRC sought to resist the taxpayers’ stay application on the basis that the domestic appeals should come first. That is striking, particularly in light of the focus on making MAPs more effective dispute resolution mechanisms as part of the BEPS project. The decision also indicates that DPT and other UK domestic anti-avoidance rules may not be immune from challenge under double tax treaties.
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