The CJEU decides, in the Gallaher case, that the UK’s legislation at the relevant time, which required an immediate tax charge without the right to deferral on a disposal of assets for market value consideration to a group company outside the UK tax net, was compliant with EU law. The recently published transfer pricing and diverted profits tax statistics show that the profit diversion compliance facility and the diverted profits tax continue to be a success for HMRC, but taxpayers face longer waiting times to agree APAs and ATCAs. The taxpayer in Harrison fails to convince the Upper Tribunal that the doctrine of staleness survived after the Supreme Court’s decision in Tooth. The Upper Tribunal in Morrisons considers when the UT can interfere in an FTT’s decision on the application of a multi-factorial test.
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The CJEU decides, in the Gallaher case, that the UK’s legislation at the relevant time, which required an immediate tax charge without the right to deferral on a disposal of assets for market value consideration to a group company outside the UK tax net, was compliant with EU law. The recently published transfer pricing and diverted profits tax statistics show that the profit diversion compliance facility and the diverted profits tax continue to be a success for HMRC, but taxpayers face longer waiting times to agree APAs and ATCAs. The taxpayer in Harrison fails to convince the Upper Tribunal that the doctrine of staleness survived after the Supreme Court’s decision in Tooth. The Upper Tribunal in Morrisons considers when the UT can interfere in an FTT’s decision on the application of a multi-factorial test.
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