Multinational groups adopting cost contribution arrangements (CCAs) — or cost share agreements in US parlance — as part of their cross-border intellectual property (IP) development strategies have a new opportunity to...more
7/9/2025
/ Corporate Taxes ,
Cross-Border ,
HM Treasury ,
HMRC ,
Intellectual Property Protection ,
International Tax Issues ,
Multinationals ,
OECD ,
Tax Planning ,
Taxation ,
Transfer Pricing ,
UK
On 28 April 2025, HM Revenue and Customs (HMRC) proposed significant reforms to the UK’s transfer pricing and permanent establishment (PE) rules, and a repeal of the diverted profits tax, bringing that regime within UK...more
On January 17, 2025, the UK Court of Appeal (Court) released its decision on whether certain members of BlueCrest Capital Management (UK) LLP (BlueCrest) should be taxed as employees under the UK “salaried members” rules (the...more