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Tax Planning Transfer Pricing United Kingdom

Skadden, Arps, Slate, Meagher & Flom LLP

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

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

Cadwalader, Wickersham & Taft LLP

UK-Perimeter Tax Rules Under the Spotlight

On 28 April 2025, the UK government launched a consultation (the “Consultation”) on proposed legislation to reform the UK’s transfer pricing (“TP”) and permanent establishment (“PE”) rules, including changes to the investment...more

Proskauer Rose LLP

UK Tax Round Up - February 2025

Proskauer Rose LLP on

Welcome to February’s edition of the UK Tax Round Up. This month has seen a number of interesting decisions covering the unallowable purpose test in relation to cross border group relief tax losses, the application of the...more

Hogan Lovells

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

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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

Proskauer - Tax Talks

Court of Appeal overturns High Court and holds that tax claim notice was valid

Proskauer - Tax Talks on

This was an appeal against the High Court decision in Dodika Ltd & Ors v United Luck Group Holdings Limited from August 2020 (see our Tax Blog on this). The case concerns the question of whether the notice given by the buyer...more

Proskauer Rose LLP

UK Tax Round Up - December 2020

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COVID-19 Developments - Tax exemptions for coronavirus antigen costs - Draft regulations providing for employee and employer national insurance contribution (NIC) exemptions from payments made to employees to cover...more

Proskauer - Tax Talks

High Court decision highlights importance of ensuring claims notices include required information

Proskauer - Tax Talks on

In Dodika Ltd & Ors v United Luck Group Holdings Limited, the High Court (HC) has accepted the sellers’ argument that a notice of a tax claim under a tax covenant served on them by the buyer was invalid because it did not...more

McDermott Will & Schulte

[Webinar] Virtual Tax Forum | Critical Tax Strategies for US MNCs with Operations in Germany, Italy, the UK and France - June 4th,...

Evolving and intersecting tax regimes are creating unintended tax exposure, as well as areas of opportunity, for multinational companies (MNCs) operating in European markets. Understand how new tax regulations transect...more

Proskauer Rose LLP

UK Tax Round Up - October 2019

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UK Case Law Developments - Reliance on HMRC's manual statement can, but didn't, give rise to legitimate expectation - In the recent judicial review case of Roao Aozora GMAC Investment Ltd v HMRC, the Court of Appeal...more

Hogan Lovells

Tech Tax – Times Are A Changing?

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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

Hogan Lovells

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

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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

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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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