2017 has been a busy year for tax disputes, both in terms of the scale and number of DPT and transfer pricing enquiries and number of significant court decisions. While litigation concerning the compatibility or otherwise of UK tax law with EU freedoms appears to be declining, the ongoing state aid investigations mean Europe will very much remain on many organisations’ radars. Likewise, the challenges of dealing with a new transfer pricing landscape and the evidential standards applied in DPT enquiries mean that both businesses and HMRC will need to commit significant resources and the full set of technical tax and dispute resolution skills in 2018 in order to resolve new and ongoing disputes.
