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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 Orsted ‘tax nothing’
Andrew Page
1 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
2 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
3 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
4 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
5 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
6 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
7 /7
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
NEWS
Read all
Conservatives pledge IHT exemption for family homes
Government accepts PAC recommendations on large business tax compliance
No breaches found under banks’ tax code
Distributions reform could hinder business transactions, CIOT warns
Bolt: Supreme Court refuses permission to appeal
CASES
Read all
HMRC v British Airways plc
Victoria Oil & Gas plc v HMRC
S Keswick and others v HMRC
Other cases that caught our eye: 9 October 2026
Jumpman Gaming Ltd v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
Bolt: Supreme Court refuses permission to appeal
Re Fulmar Contracting Ltd (In Liquidation) and others v M Williams and another
HMRC name 196 deliberate tax defaulters
Victoria Oil & Gas plc v HMRC
Loans to participators: s 455