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Diverted profits tax
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Diverted profits tax
DIVERTED-PROFITS-TAX
DPT notices and APAs: the implications of Refinitiv
Paula Ruffell
Astrid Vroom
Paula Ruffell and Astrid Vroom (
EY)
consider the implications of
Refinitiv
to transfer pricing methodologies adopted in multiple years and what this means for APAs and DPT assessments more generally.
R (o.a.o Refinitiv Ltd and others) v HMRC
No inconsistency between DPT notices and terms of advance pricing agreement.
Tax and the City review for October 2023
Zoe Andrews
Mike Lane
Tricky timings, difficult delineations, punitive payments... Mike Lane and
Zoe Andrews (Slaughter and May) review the latest developments that matter.
Diverted profits tax reform: is this the end of the diversion?
Kara Heggs
Alex Jupp
The proposed reforms to the diverted profits tax would, if implemented, take some of the venom out of DPT’s ‘sting’, write Alex Jupp and Kara Heggs (Skadden).
Reviewing HMRC’s consultation on transfer pricing reform
Bezhan Salehy
Deep Shah
Bezhan Salehy and Deep Shah (Macfarlanes) review the government’s extensive package of proposals that touch most areas of the UK’s transfer pricing, permanent establishment and diverted profits tax legislation.
Getting closure in transfer pricing and DPT enquiries
Tom Gilliver
Tom Gilliver (Slaughter and May) considers the procedural challenges that arise from the interaction between the transfer pricing and diverted profits tax rules.
Tax and the City review for November 2021
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) consider Autumn Budget/Finance Bill measures relevant to financial institutions and the latest on international tax reform.
International business operating models: the tax issues
Gavin Orpwood
Louise Keegan
Hannah McKenzie
Hannah McKenzie, Louise Keegan and Gavin Orpwood (PwC) examine the
tax risks to international business operating models.
Diverted profits investigations update
Jack Prytherch
Jack Prytherch (Bird & Bird) discusses what HMRC will look for in an investigation and the steps MNEs can take to protect themselves.
UK tax pitfalls of the foreign company
Laura Hoyland
Elizabeth Emerson
Laura Hoyland and Elizabeth Emerson (White & Case) explain the various bear-traps for a foreign company proposing to do business in the UK.
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of
4
EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
Consultation launched on extending UTT regime
Finance Bill completes parliamentary stages
Regulations set 2026/27 NIC rates and extend veterans relief
Further NIC re-rating provisions for 2026/27
Voluntary NIC window for those abroad closes soon
CASES
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Muller UK and Ireland Group LLP and others v HMRC
Countrywide Partners Ltd v HMRC
S Kamal v Tax Policy Associates Ltd and another
Other cases that caught our eye: 20 March 2026
CooperVision Lens Care Ltd v HMRC
IN BRIEF
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
New SDLT burden for private renters
Transactions in Securities counteraction notices
MOST READ
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CooperVision Lens Care Ltd v HMRC
Consultation tracker
Transactions in Securities counteraction notices
Capital by name, income in nature: the Upper Tribunal’s decision in BCG
Finance Bill 2026 progress