TRANSFER-PRICING

Philippe Gamito (Baker McKenzie) examines a year of significant VAT case law, from transfer pricing adjustments and debt-collection boundaries to the evolving scope of insurance and credit intermediation.

Eloise Walker

When I originally suggested writing this comment piece, I thought I was going to be writing about exciting changes in partnership taxation, and various other interesting developments in the world of corporate tax. That all went out the window before...

Lauren Redhead

Ravi Ahlawat

Lauren Redhead and Ravi Ahlawat (DLA Piper) consider what to do when HMRC enquire into deal funding, and provide a practical playbook from first request to resolution.

Mark Bevington

Mark Bevington (ADE Tax) highlights the areas where the new TP and UTPP rules do not appear to work as intended.

Sophie Dworetzsky

In this month’s review, Sophie Dworetzsky (Charles Russell Speechlys) examines a case on distributions from an offshore company, a potentially farreaching proposed change to the definition of permanent establishment and the latest HMRC guidance.

Transfer pricing adjustments can fall within the scope of VAT

Closure notices, DPT and transfer pricing

Phil Maggs

Phil Sneade

Phil Maggs and Phil Sneade (Frontier Economics) explain why it is usually wrong to argue for a ‘risk-free’ return for capital at arm’s length.

Robert Langston

Robert Langston (Saffery) explains why it is necessary to consider international tax principles, such as entity classification and transfer pricing, alongside the disguised investment management fee rules.