Recent cases, including Embiricosand Vitol, have clarified the circumstances in which taxpayers can bring finality to protracted enquiries by applying to the court for the issuance of closure notices. However, the taxpayer’s victory in Vitol has been partly superseded by amendments to the diverted profits tax rules. Practitioners should be alert to the technical and procedural challenges that can now arise in the context of enquiries that involve both transfer pricing and diverted profits tax, due to the complex interaction between the two.
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Recent cases, including Embiricosand Vitol, have clarified the circumstances in which taxpayers can bring finality to protracted enquiries by applying to the court for the issuance of closure notices. However, the taxpayer’s victory in Vitol has been partly superseded by amendments to the diverted profits tax rules. Practitioners should be alert to the technical and procedural challenges that can now arise in the context of enquiries that involve both transfer pricing and diverted profits tax, due to the complex interaction between the two.
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:
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