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Where is the Wider Context?

Chris Morgan Partner in charge and Jonathan Bridges Manager KPMG's EU Group consider the proposed changes in the Condoc to the existing transfer pricing and thin capitalisation legislation
As expected the latest consultation document (Condoc) on corporation tax reform issued jointly by the Treasury and Inland Revenue on 12 August includes proposals aimed at ensuring the UK corporation tax system is '… kept robust against any legal challenges under EU law'.
This article considers the proposed changes to the existing transfer pricing and thin capitalisation legislation and highlights a number of concerns. Thought is then given to further EU developments which we may expect in the near future and how the Government's current approach may need to change if we are to progress from...

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