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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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3
EDITOR'S PICK
The new Securities Transfer Tax: business as usual?
Georgina West
1 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
2 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
3 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
4 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
5 /7
Estoppel and abuse of process in VAT
Claire Logan
6 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
7 /7
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
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
NEWS
Read all
Tax Journal thanks its July 2026 authors
GAAR Advisory Panel issues Opinions on IHT planning arrangements
CIOT and ATT suggest priorities for new Financial Secretary
Pillar Two top-up taxes returns: deadline reminder
ATT cautions against ITSA ‘timely payment’ reforms
CASES
Read all
Ten cases shaping tax practice in 2026
New cases this week: 31 July 2026
M Elborne and others v HMRC
E Kwai v HMRC
P Reed v HMRC
IN BRIEF
Read all
Funding the business
HMRC’s annual report for 2025/26
The new duty to correct tax return errors
The VAT treatment of prize draws
Directors’ liability: tax schemes
MOST READ
Read all
The VAT treatment of prize draws
The new duty to correct tax return errors
Loan charge settlement scheme: regulations and guidance published
Requirements for forthcoming pensions IHT changes
One minute with... Tim Gummer