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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
Cristy Ajediti
Helen Coward
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
Monia Volpato
Rachit Agarwal
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
Chris Sanger
Jack Gifford
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
Lucy Urwin
Gregory Price
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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of
3
EDITOR'S PICK
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
1 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
2 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
3 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
4 /7
The new Securities Transfer Tax: business as usual?
Georgina West
5 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
6 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
7 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
NEWS
Read all
OECD issues Pillar Two review framework and revised GIR
VAT refund policy change for non-UK members of VAT groups
VAT on fund management services: new HMRC guidelines
Temporary zero rate for domestic electricity
CBAM admin regulations published
CASES
Read all
J Scheckter v HMRC
Luxurico Ltd v HMRC
C Sagar v HMRC
Other cases that caught our eye: 18 September 2026
The Executors of Hunt and others v HMRC
IN BRIEF
Read all
TOGCs and leases
Principal or agent?
HMRC get more bang for their buck
Sanctionable conduct
The end of offshore execution on secondary transactions
MOST READ
Read all
Grand Smile Design Ltd v HMRC
Raising standards without regulating the profession
Consultation tracker
The Executors of Hunt and others v HMRC
HMRC manual changes: 4 September 2026