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Potential additional hurdle to clear if interest on intra-group debt is to be tax deductible in the UK

In applying the UK’s transfer pricing rules, tax advisers have to think beyond the amount of the debt and the interest rate to get comfortable that an intra-group loan is going to be tax deductible. Following a recent case,...more

Tech Tax – Looking Forward to 2020

Following-up from our previous blogs on Tech Tax, we thought it would be useful to take a whirlwind tour of what to expect in tax and transfer pricing related topics in 2020. But for those that are curious, why are such...more

Tech Tax and the OECD: it’s as easy as A, B, C

What is it about? OECD proposals to tax the digital economy which will significantly impact all large tech companies that are consumer oriented. What will the impact be? Businesses will pay more tax. Impact on cash-flow,...more

Tech Tax – Times Are A Changing?

It’s been a busy month in the world of tax for tech companies. France and the UK are introducing digital services taxes, and serious work is underway at the OECD that may result in a shake-up of the international tax system...more

UK Tax Authority tightens the screws on tech companies

HMRC announced today the introduction of their new Profits Diversion Compliance Facility (PDCF). This is a way for multinationals to take the initiative and explain their legal and operational structures before HMRC launch...more

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