This article focuses on the taxation of corporates: direct tax, indirect tax and transfer pricing. Reduced focus on marketed avoidance and EU disputes by HMRC may lead to increased activity on other corporate tax issues. Many key VAT disputes continue into 2014, including Littlewoods and ATP PensionService. Transfer pricing disputes are likely to have a particular focus on IP issues, as well as difficulties in dealing with countries that are not OECD-compliant. Changes to HMRC’s practical and policy approach to dispute resolution continue to bed in. Corporates seeking to resolve a dispute will still have to expect to take the lead.
