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 in the same group (UKCOs) with the fourth a group company that had provided an indemnity over tax liabilities affected by the claims. The UT dismissed the claims finding that an arm’s length transfer pricing (TP) methodology agreed in an APA only applies in...
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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 in the same group (UKCOs) with the fourth a group company that had provided an indemnity over tax liabilities affected by the claims. The UT dismissed the claims finding that an arm’s length transfer pricing (TP) methodology agreed in an APA only applies in...
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