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Dpt
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Dpt
DPT
TP, DPT and UTPP: twists, turns and transformations
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.
Refinitiv Ltd and others v HMRC
Closure notices, DPT and transfer pricing
Tax and the City review for January 2025
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.
R (oao Refinitiv Ltd and others) v HMRC
Court of Appeal dismisses DPT judicial review.
Tax and the City review for February 2024
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).
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).
Tax and the City review for July 2023
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.
Tax and the City review for March 2023
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.
Vitol Aviation, closure notices and DPT enquiries: ‘enough already’?
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.
Time limit traps: lessons from the 2019 loan charge
Richard Jeens
Rose Swaffield
The 2019 loan charge teaches us that there is more to statutory time limits than the technical analysis, write Richard Jeens and Rose Swaffield (Slaughter and May).
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EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
HMRC manual changes: 5 September 2025
Pre-Budget speculation fuels rumours of bank windfall tax and landlord NICs
Submitting RIF notifications to HMRC
HMRC guidelines on declarations of accuracy and completeness
EV charging added to advisory fuel rates
CASES
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Lexgreen Services Ltd v HMRC
Elphysic Ltd and others v HMRC
W Tinkler v HMRC
Clear Pay Payroll Ltd v HMRC
Other cases that caught our eye: 5 September 2025
IN BRIEF
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Closing the tax gap: HMRC’s approach to ‘legal interpretation disputes’
CenTax recommends changes to protect family farms
Soft Drinks Industry Levy credit repayments
Self’s assessment: Time for a wealth tax?
Highlights from HMRC’s 2024/25 annual report
MOST READ
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First failure to prevent the facilitation of tax evasion case
T Masters v HMRC
Government mulls reforms to property taxes
Government mulls reforms to property taxes
United Carpets (Franchisor) Ltd v HMRC