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Brief
On 10/01/2025, Her Majesty's Revenue and Customs (HMRC) issued an update regarding International Manual. The document covers international tax issues including principles of double taxation relief and introduction to double taxation agreements, as well as topics such as controlled foreign companies, non-residents trading in the UK, transfer pricing, diverted profits tax, intra-group funding, thin capitalisation, hybrids, and immunities and privileges.
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