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TRANSFER-PRICING


In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider the Court of Appeal decisions in Royal Bank of Canada and Civic Environmental Systems and the consultation on transfer pricing, DPT and permanent establishment. 
Card image Clara Boyd, Lauren Redhead, Emily Burke
Clara Boyd, Lauren Redhead and Emily Burke (DLA Piper) review the changing contentious tax landscape, including the courts continuing efforts on improving procedural certainty.
James Shorland (Alvarez and Marsal) explores some of the unintended UK tax consequences of master holdco structures on portfolio companies of private equity funds. 
Mike Lane and Zoe Andrews (Slaughter and May) examine recent decisions of interest and the latest transfer pricing and diverted profits tax statistics.
When structuring a UK acquisition, there are a myriad of tax issues to consider, as Helena Kanczula (BKL) explains.
The Upper Tribunal decisions in Altrad Services, BlackRock and Euromoney are examined by Mike Lane and Zoe Andrews (Slaughter and May).
The latest on BEPS, tax transparency and transfer pricing, reviewed by Tim Sarson (KPMG). 
BEPS 2.0 and the US FY 2023 Budget are among the recent developments examined by Tim Sarson (KPMG).
OECD commentary on the pillar two model rules and the responses to the pillar one public consultations are among the recent developments examined by Tim Sarson (KPMG). 
Tom Gilliver (Slaughter and May) considers the procedural challenges that arise from the interaction between the transfer pricing and diverted profits tax rules.
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