The Upper Tribunal in Union Castle agrees with HMRC that the issue of shares is a ‘provision’ to which transfer pricing can apply. The recently published diverted profits tax statistics show a steep increase in both the numbers of notifications by companies and the preliminary notices and charging notices issued by HMRC. The AG’s opinion in C&D Foods, if followed by the CJEU, may call into question the UK’s treatment of input tax on costs where an intended share sale is aborted.
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