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Transfer pricing
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Transfer pricing
TRANSFER PRICING
BlackRock: no imputation of covenants for transfer pricing purposes
Paul Sutton
The Upper Tribunal’s decision on the transfer pricing aspects of the
BlackRock
case is an overly restrictive interpretation of the law, writes Paul Sutton (LCN Legal).
Transfer pricing: new guidance on hard to value intangibles
Vladimir Milic
Anton Hume
The guidance on HTVIs is likely to have a considerable impact on the development of transfer pricing compliance, write Vladimir Milic and Anton Hume (BDO).
Transfer pricing: documentation proposals and disputes
Sarah Bond
Sarah Bond (Freshfields Bruckhaus Deringer) considers the implications for businesses of the proposed changes to required transfer pricing documentation currently under consultation.
Covid-19 and transfer pricing
Five key lessons from the OECD’s new guidance.
Transfer pricing guide to cash pooling arrangements
Daniel J. Pugh
John W. Lamszus
Selena Schneider
Selena Schneider, John W. Lamszus and Daniel J. Pugh (Crowe) provide a guide to this common treasury management tool used by multinationals to efficiently manage cash and reduce process and transaction costs.
Transfer pricing for financial transactions: what just changed?
Fan Bai
Clive Jie-A-Joen
Monique van Herksen
The OECD's new guidance marks a change in approach, as experts at Simmons & Simmons explain.
The transfer pricing of financing transactions: OECD guidance
Andrew Stewart
Anton Hume
We are expecting new OECD guidance on the transfer pricing analysis of financing arrangements. Anton Hume and Andrew Stewart (BDO) consider what’s most likely to change.
How to handle HMRC transfer pricing enquiries
Ben Henton
Paul Daly
Transfer pricing enquiries are becoming a commonplace challenge within the UK tax landscape. Paul Daly and Ben Henton (BDO) examine the practical issues.
FA 2019: hybrid mismatch rule
Richard Cherrett
In 2017, the UK implemented a detailed set of hybrid mismatch rules to combat cross-border tax advantages arising from hybridity for example, the differing tax treatments of entities, transactions or instruments. The...
Valuing management charges for VAT purposes
Anton Hume
Is the arm’s length principle about to enfold VAT?
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EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
NEWS
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UK posts record January budget surplus following increased tax receipts
HMRC guidance on R&D relief in the creative sector
Deferred remuneration for globally mobile employees
New guidance on registering for VAT IOSS scheme
Devolved Scottish Aggregates Tax to take effect from 1 April 2026
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Lycamobile UK Ltd v HMRC
A Ferguson and another v HMRC
Genuine Care Homecare Services Ltd v HMRC
Other cases that caught our eye: 27 February 2026
MWL International Ltd
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Crypto things
Tax efficient trust planning with surplus income
Suspended penalties
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Concerns over the scope of new conduct rules for advisers
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Exchequer Secretary defends tax adviser registration regime as Law Society warns of market impact
Mandatory agent registration: what we know so far
Deductions after AD Bly: a shortcut for remuneration or pension provision?
Alimahomed: the Upper Tribunal gives ‘remittance’ a real world interpretation
Consultation tracker