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Transfer pricing
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Transfer pricing
TRANSFER-PRICING
The CIR and related party guarantees: a case study for a privately owned UK group
Robert Langston
Robert Langston (Saffery) provides a practical case study on the operation
of the corporate interest restriction where related party guarantees and
withholding tax issues are involved.
BlackRock Holdco 5 LLC v HMRC
Court of Appeal overturns Upper Tribunal decision on transfer pricing but upholds conclusion on unallowable purpose.
HMRC’s new transfer pricing guidance on risk and reward
Charles Havisham
Phil Roper
The thrust of HMRC’s guidance is to reject the notion that a profit split
shouldn’t be used to reward risk control contributions, write Phil Roper and
Charles Havisham (KPMG).
Tax and the City review for February 2024
Zoe Andrews
Mike Lane
The Court of Appeal’s decision in
Dolphin Drilling
and consultation responses on the modernisation of transfer pricing, DPT and PEs are among the recent developments in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
Failing to sense the mood music: the AG’s opinion in Commission v Ireland and Apple
Stephen Daly
It is highly unlikely that the CJEU will follow Advocate General Pitruzzella’s opinion in the Apple state aid case, writes Stephen Daly (King’s College London).
Transfer pricing and intangibles: are all the issues priced in?
Alex Rigby
James Anderson
James Anderson and Alex Rigby (Skadden) examine HMRC’s package of
proposed transfer pricing reforms, and consider how they might assist with
existing uncertainty and double taxation disputes.
International review for October 2023
Tim Sarson
The international tax world is still dominated by BEPS 2.0 developments,
reports Tim Sarson (KPMG). This article includes an update on the national
implementation of Pillar Two.
Tax and the City review for October 2023
Zoe Andrews
Mike Lane
Tricky timings, difficult delineations, punitive payments... Mike Lane and
Zoe Andrews (Slaughter and May) review the latest developments that matter.
Tax and the City review for July 2023
Zoe Andrews
Mike Lane
In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider the Court of Appeal decisions in Royal Bank of Canada and Civic Environmental Systems and the consultation on transfer pricing, DPT and permanent establishment.
Contentious tax: 2023 mid-year review
Lauren Redhead
Emily Burke
Clara Boyd
Clara Boyd, Lauren Redhead and Emily Burke (DLA Piper) review the changing contentious tax landscape, including the courts continuing efforts on improving procedural certainty.
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EDITOR'S PICK
The Orsted ‘tax nothing’
Andrew Page
1 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
2 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
3 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
4 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
5 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
6 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
7 /7
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
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
NEWS
Read all
Conservatives pledge IHT exemption for family homes
Government accepts PAC recommendations on large business tax compliance
No breaches found under banks’ tax code
Distributions reform could hinder business transactions, CIOT warns
Bolt: Supreme Court refuses permission to appeal
CASES
Read all
HMRC v British Airways plc
Victoria Oil & Gas plc v HMRC
S Keswick and others v HMRC
Other cases that caught our eye: 9 October 2026
Jumpman Gaming Ltd v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
Bolt: Supreme Court refuses permission to appeal
Re Fulmar Contracting Ltd (In Liquidation) and others v M Williams and another
HMRC name 196 deliberate tax defaulters
Victoria Oil & Gas plc v HMRC
Loans to participators: s 455