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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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60
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
HMRC name 196 deliberate tax defaulters
Re Fulmar Contracting Ltd (In Liquidation) and others v M Williams and another
Loans to participators: s 455
Modernising the taxation of distributions
One minute with... Tom Margesson