DPT

Wai Wan Bahar Eken Gideon Sanitt

Gideon Sanitt, Wai Wan and Bahar Eken (Macfarlanes) explain why multinationals operating in the UK should expect a more demanding transfer pricing landscape.

David Haughey Sarah Bond Edward Buxton

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).

Sarah Bond

Benjamin Crompton

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

Mike Lane

Zoe Andrews

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.

Mike Lane

Zoe Andrews

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).

Alex Jupp

Kara Heggs

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).

Mike Lane

Zoe Andrews

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.

Mike Lane

Zoe Andrews

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

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