TRANSFER PRICING

Ros Martin

Consultant Ros Martin provides an overview of this year’s Finance Act, including reforms to income tax and inheritance tax, the recast carried interest regime, changes to capital allowances and venture capital schemes, and expanded compliance and anti-avoidance provisions.

Réka Mező

Kapisha Vyas

AG Kokott calls for a principled approach to the VAT treatment of transfer pricing adjustments – and questions the legacy of Arcomet, write Kapisha Vyas and Réka Mező (Simmons & Simmons).

David Haughey Sarah Bond Edward Buxton

The Finance Bill rules introduce further complexity to the earlier draft provisions and place an unwelcome reliance on HMRC guidance, write Sarah Bond, Edward Buxton and David Haughey (Freshfields).

Philippe Gamito

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.

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.

Gary Barnett

Jo Crookshank

Jo Crookshank and Gary Barnett (Simmons & Simmons) provide this month’s round-up of the latest VAT developments, including two CJEU rulings.

Guy Bud

Giles Salmond

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.

Andrew Stewart

Amy Clarke

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.

Giles Salmond

Giles Salmond (Stewarts) considers the impact of a recent CJEU judgment on the nature and valuation of intra-group management services.

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).

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