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).

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.

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 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.

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.

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).

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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