News & Analysis as of

HMRC › Multinationals › Tax Planning

Skadden, Arps, Slate, Meagher & Flom LLP

Towards Commercial Rationality: HMRC’s New Unilateral APA Process Will Reduce Uncertainty Over Cost-Sharing Participation

Skadden, Arps, Slate, Meagher & Flom LLP on

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

Hogan Lovells

UK: IP tax diversion compliance – time to review your IP transfer pricing structure

Hogan Lovells on

The UK tax authority (HMRC) has announced a new Profits Diversion Compliance Facility (PDCF), as part of its efforts to ensure that multinationals do not use artificial arrangements to divert profit to lower tax...more

Hogan Lovells

UK Tax Authority tightens the screws on tech companies

Hogan Lovells on

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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