DPT

Edward Buxton David Haughey Sarah Bond

The Finance Bill rules introduce further complexity to the earlier draft provisions and place an unwelcome reliance on HMRC guidance, write Sarah Bond, Edward Buxton and David Haughey (Freshfields).

Benjamin Crompton

Sarah Bond

Sarah Bond and Benjamin Crompton (Freshfields) examine the draft legislation that amends certain aspects of the rules on transfer pricing and the diverted profits tax.

Closure notices, DPT and transfer pricing

Zoe Andrews

Mike Lane

This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) covers the decisions in Refinitiv, Syngenta and Cobalt and HMRC’s updated guidance on share exchanges.

Court of Appeal dismisses DPT judicial review.

Zoe Andrews

Mike Lane

The Court of Appeal’s decision in Dolphin Drilling and consultation responses on the modernisation of transfer pricing, DPT and PEs are among the recent developments in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).

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).

Zoe Andrews

Mike Lane

In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider the Court of Appeal decisions in Royal Bank of Canada and Civic Environmental Systems and the consultation on transfer pricing, DPT and permanent establishment.

Zoe Andrews

Mike Lane

Mike Lane and Zoe Andrews (Slaughter and May) examine recent decisions of interest and the latest transfer pricing and diverted profits tax statistics.

Jon Preshaw

Craig Thomson

Craig Thomson (CSM Tax Consulting) and Jon Preshaw (Jon Preshaw Tax Ltd) examine a recent tribunal decision that provides useful guidance on HMRC information requests and closure notices in the context of DPT enquiries.

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