The discussion of the meaning of ‘incidental’ by the Court of Appeal in Dolphin Drilling may be of interest in other contexts such as for determining whether something is a main purpose under the loan relationship unallowable purpose rule. The summary of responses to the consultation on the modernisation of transfer pricing, diverted profits tax and permanent establishments confirms a number of proposed changes (including incorporating the DPT regime as part of corporation tax) and highlights changes still under consideration. HMRC publishes the latest statistics on transfer pricing and DPT which include that DPT has secured more than £8.5bn of revenue from when DPT was first introduced to the end of 2022/23. The latest OECD statistics show that ICAP is working effectively for MNEs and tax administrations with 20 cases completed by October 2023 and more in progress.
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The discussion of the meaning of ‘incidental’ by the Court of Appeal in Dolphin Drilling may be of interest in other contexts such as for determining whether something is a main purpose under the loan relationship unallowable purpose rule. The summary of responses to the consultation on the modernisation of transfer pricing, diverted profits tax and permanent establishments confirms a number of proposed changes (including incorporating the DPT regime as part of corporation tax) and highlights changes still under consideration. HMRC publishes the latest statistics on transfer pricing and DPT which include that DPT has secured more than £8.5bn of revenue from when DPT was first introduced to the end of 2022/23. The latest OECD statistics show that ICAP is working effectively for MNEs and tax administrations with 20 cases completed by October 2023 and more in progress.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
