INTRA-GROUP

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).

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.

Giles Salmond

Giles Salmond (Stewarts) considers the impact of a recent CJEU judgment on the nature and valuation of intra-group management services.

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.

Capital allowances: ring fence trades and intra-group transfers

Supply of intra-group services was a single composite taxable supply

Katie Oliver

Gary Barnett

Katie Oliver and Gary Barnett (Simmons & Simmons) examine this month’s key VAT developments.

Court of Appeal overturns Upper Tribunal decision on transfer pricing but upholds conclusion on unallowable purpose.

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).

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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