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Briefing

MAPping unchartered territory

Freshfields London Tax team successfully acted for Glencore before the First-tier Tribunal in relation to a recent stay application requested by two Glencore entities (one UK resident and one Swiss resident) which are appealing various corporation tax and diverted profits tax (DPT aka ‘Google tax’) assessments. The decision offers some important insights into the interaction between domestic appeals and mutual agreement procedures (or “MAPs”) which are provided for in double tax treaties.

David Haworth, Emily Szasz and Charlotte Anderson explore the First-tier Tribunal’s decision in more detail in the briefing at the link below.