Paula Ruffell and Astrid Vroom (EY) consider the implications of Refinitiv to transfer pricing methodologies adopted in multiple years and what this means for APAs and DPT assessments more generally.
On 20 October 2023 the Upper Tribunal (UT) judgment in R (on the application of) Refinitiv Ltd and others v HMRC [2023] UKUT 257 (TCC) was released.
The four claimants in this case brought a judicial review claim against HMRC’s decision to issue Diverted Profits Tax (DPT) notices on the claimants charging them to DPT in the aggregate amount of approximately £167m. Three of the claimants were UK tax-resident companies at that time...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
Paula Ruffell and Astrid Vroom (EY) consider the implications of Refinitiv to transfer pricing methodologies adopted in multiple years and what this means for APAs and DPT assessments more generally.
On 20 October 2023 the Upper Tribunal (UT) judgment in R (on the application of) Refinitiv Ltd and others v HMRC [2023] UKUT 257 (TCC) was released.
The four claimants in this case brought a judicial review claim against HMRC’s decision to issue Diverted Profits Tax (DPT) notices on the claimants charging them to DPT in the aggregate amount of approximately £167m. Three of the claimants were UK tax-resident companies at that time...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
