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Transfer pricing
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Transfer pricing
TRANSFER PRICING
Forex: recent UK tax developments
Tamar Ruiz
Matthew Mortimer
Matthew Mortimer and Tamar Ruiz (Mayer Brown) examine key recent
changes to the UK taxation of foreign exchange gains and losses.
The VAT review for October 2025
Jo Crookshank
Gary Barnett
Jo Crookshank and Gary Barnett (Simmons & Simmons) provide this month’s round-up of the latest VAT developments, including two CJEU rulings.
Arcomet Towercranes: the VAT consequence of transfer pricing adjustments
Giles Salmond
Guy Bud
Giles Salmond and Guy Bud (Stewarts) assess the impact of a recent
CJEU ruling on the VAT treatment of intra-group transfer pricing adjustments
and the limits of tax authority powers to challenge input tax recovery.
The ICTS: a new chapter in transfer pricing compliance
Amy Clarke
Andrew Stewart
The International Controlled Transaction Schedule is expected to be
introduced in the UK in the foreseeable future. Andrew Stewart and
Amy Clarke (BDO) explain how to prepare.
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.
Parallel tracks
Phil Maggs
Phil Sneade
A common set of economic principles and methods underpins state aid,
competition and arm’s length analysis, write Phil Sneade and Phil Maggs
(Frontier Economics).
TP, DPT and UTPP: twists, turns and transformations
Benjamin Crompton
Sarah Bond
Sarah Bond and Benjamin Crompton (Freshfields) examine the draft
legislation that amends certain aspects of the rules on transfer pricing and the
diverted profits tax.
Lifecycle of a transaction: transfer pricing considerations
Uwe Zoellner
Rachit Agarwal
Monia Volpato
Rachit Agarwal, Monia Volpato and Uwe Zoellner (DLA Piper) set
out the transfer pricing aspects that should be considered during the
acquisition process.
The VAT review for May 2025
Jo Crookshank
Gary Barnett
VAT developments concerning transfer pricing adjustments, tripartite
arrangements and the Tour Operators Margin Scheme are examined in this
month’s review by Jo Crookshank and Gary Barnett (Simmons & Simmons).
Transfer pricing: why returns are rarely risk-free
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.
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EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
HMRC manual changes: 10 October 2025
Government no closer on wealth tax
ATT launches MTD ‘digital readiness tips’ for agents
R&D claims down but support remains stable
Reactivating clients’ self-assessment accounts
CASES
Read all
GW Martin & Co Ltd and another v HMRC
A Weis v HMRC
Other cases that caught our eye: 10 October 2025
Isle of Wight NHS Trust v HMRC
Jumpman Gaming Ltd v HMRC
IN BRIEF
Read all
HMRC’s new NIC guidance on internationally mobile employees
The tax Budget cycle
More on s 455
What if HMRC win in Hotel la Tour?
Supreme Court in Prudential Assurance
MOST READ
Read all
HMRC’s new NIC guidance on internationally mobile employees
Jumpman Gaming Ltd v HMRC
Isle of Wight NHS Trust v HMRC
GfC 13 and the filing position: nothing to see here?
Legislating against promoters of marketed tax avoidance scheme