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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
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Loopholes and tax avoidance
Kyle Rainsford
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
NEWS
Read all
Tax Update 2026: government publishes simplification and compliance package
HMRC asked to clarify CIS treatment of development finance
HMRC Transfer Pricing and Profit Diversion Compliance Facility
ICTS consultation
UK-India Double Contributions Convention arrangements extended
CASES
Read all
HMRC v HFFX LLP; Atkins and others v HMRC
The Trustees of the Panico Panayi Accumulation and Maintenance Settlements Nos. 1 to 4 v HMRC and Redevco Properties UK 1 Ltd v HMRC
Other cases that caught our eye: 26 June 2026
HMRC v Bolt Services UK Ltd
Barclays Bank plc v HMRC
IN BRIEF
Read all
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
Information notices
Management rollovers and share-for-share exchange relief
MOST READ
Read all
Solving the LLC double taxation problem
Consultation tracker
Foreign PE exemption becoming mandatory
HMRC v GCH Corporation Ltd and others
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’