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INTRA-GROUP
UK to UK transfer pricing: what the recent changes mean for VAT
Lyndon Firth
Swati Thapa
The removal of UK-to-UK transfer pricing will shift VAT to the forefront of domestic intra-group compliance, write Lyndon Firth and Swati Thapa (BDO).
Complex statutory construction: the Court of Appeal’s approach in Tower One
Helen Coward
Cristy Ajediti
Helen Coward and Cristy Ajediti (Simmons & Simmons) explain why Tower One is another warning on the risks of complex, tax-driven arrangements.
Can transfer pricing leave the VAT analysis lost on a high hill?
Giles Salmond
Giles Salmond (Stewarts) considers the impact of a recent CJEU judgment on
the nature and valuation of intra-group management services.
Lifecycle of a transaction: transfer pricing considerations
Uwe Zoellner
Rachit Agarwal
Monia Volpato
Rachit Agarwal, Monia Volpato and Uwe Zoellner (DLA Piper) set
out the transfer pricing aspects that should be considered during the
acquisition process.
CATS North Sea Ltd v HMRC
Capital allowances: ring fence trades and intra-group transfers
JPMorgan Chase Bank NA v HMRC
Supply of intra-group services was a single composite taxable supply
The VAT review for May 2024
Katie Oliver
Gary Barnett
Katie Oliver and Gary Barnett (Simmons & Simmons) examine this month’s
key VAT developments.
BlackRock Holdco 5 LLC v HMRC
Court of Appeal overturns Upper Tribunal decision on transfer pricing but upholds conclusion on unallowable purpose.
The saga continues: implementing Pillar Two in the UK
Jack Gifford
Chris Sanger
The UK’s approach may require taxpayers to take a leap of faith that the final legislation will align with the GloBE rules, write Chris Sanger and
Jack Gifford (EY).
LLPs and intangibles: avoiding traps in M&A and intra-group transfers
Gregory Price
Lucy Urwin
Gregory Price and Lucy Urwin (Macfarlanes) discuss the challenges of dealing with LLPs in the context of M&A and group reorganisations in light of recent case law.
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3
EDITOR'S PICK
ScottishPower and penalties: McKnight sent off
Rupert Shiers
,
Katharine Crossman
1 /7
From sovereign immunity to sovereign tax status
Tom Margesson
,
Elena Rowlands
2 /7
Founders’ Relief: a narrow route to 10%
Hannah Magee
,
Charlotte Senior
,
Martin Verrall
3 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
4 /7
The Orsted ‘tax nothing’
Andrew Page
5 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
6 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
7 /7
ScottishPower and penalties: McKnight sent off
Rupert Shiers
,
Katharine Crossman
From sovereign immunity to sovereign tax status
Tom Margesson
,
Elena Rowlands
Founders’ Relief: a narrow route to 10%
Hannah Magee
,
Charlotte Senior
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
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
NEWS
Read all
Finance Bill 2027 published: key measures
International Controlled Transaction Reporting Regulations published
Tax treatment of image rights payments: new draft guidance
SAYE bonus rates increased
ADT: Highlands and Islands exemption
CASES
Read all
Hogan Lovells Cadwalader International LLP v HMRC
HMRC v The Mersey Docks and Harbour Company Ltd
Bottled Science Ltd v HMRC
R (Thomas Holdings Ltd and others) v HMRC
Another case that caught our eye: 13 November 2026
IN BRIEF
Read all
Employees’ expenses
Closing the tax gap: what should taxpayers expect?
Interest withholding tax: a partial solution
Founders’ Relief
Distributions reform: unresolved questions
MOST READ
Read all
Founders’ Relief: a narrow route to 10%
Tax Journal's 2026 Budget coverage
New HMRC withholding tax guidance
Budget 2026: Sovereign immunity - a more considered reform
Distributions reform: unresolved questions