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Managing overseas tax disputes

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FTSE 100 companies are more likely to have tax disputes overseas than with HMRC. While HMRC plays with a ‘straight-bat’, and the tax tribunal is rigorous and fair, overseas tax authorities may be under-resourced, susceptible to political influence, even corrupt; the legal framework may be ambiguous, and the rule of law compromised. Agreements with government as to tax payable may be unenforceable if they conflict with the legislation. Avoiding disputes is better than trying to resolve them once they arise. But some disputes are simply unavoidable. With the right advice and strategy, companies will be better placed to resist such demands.

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