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TRANSFER-PRICING


James Shorland (Alvarez and Marsal) explores some of the unintended UK tax consequences of master holdco structures on portfolio companies of private equity funds. 
Mike Lane and Zoe Andrews (Slaughter and May) examine recent decisions of interest and the latest transfer pricing and diverted profits tax statistics.
When structuring a UK acquisition, there are a myriad of tax issues to consider, as Helena Kanczula (BKL) explains.
The Upper Tribunal decisions in Altrad Services, BlackRock and Euromoney are examined by Mike Lane and Zoe Andrews (Slaughter and May).
The latest on BEPS, tax transparency and transfer pricing, reviewed by Tim Sarson (KPMG). 
BEPS 2.0 and the US FY 2023 Budget are among the recent developments examined by Tim Sarson (KPMG).
OECD commentary on the pillar two model rules and the responses to the pillar one public consultations are among the recent developments examined by Tim Sarson (KPMG). 
Tom Gilliver (Slaughter and May) considers the procedural challenges that arise from the interaction between the transfer pricing and diverted profits tax rules.
Card image Elena Rowlands Ian Zeider Emily Clark
Emily Clark, Elena Rowlands and Ian Zeider (Travers Smith) give an overview of, and their verdict on, the QAHC legislation in the Finance Bill. 
James McCredie (Macfarlanes) reviews a hugely welcome new regime, but explains there are still some ‘shoot in foot’ opportunities that it is to be hoped the government and HMRC will resist.
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