Rupert Shiers and Graham Poole (Hogan Lovells) review the likely areas for disputes in the coming year.
With the start of 2017 we reflect again on tax disputes issues. There remains pressure on tax authorities to increase yield. International tax planning remains under press scrutiny. Partly for these reasons we believe transfer pricing and diverted profits tax (DPT) will be key areas of dispute. They are a significant focus of this article. For the remainder we focus on VAT (and thank our colleague Lee Squires for that material).
DPT and the 12 month period
By the time of this article it will be widely understood that HMRC has issued its first DPT charging notices for the period to 31 December 2015. It seems likely that more will follow shortly: there is always a focus on yield in the lead-up to the end of HMRC’s reporting...
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Rupert Shiers and Graham Poole (Hogan Lovells) review the likely areas for disputes in the coming year.
With the start of 2017 we reflect again on tax disputes issues. There remains pressure on tax authorities to increase yield. International tax planning remains under press scrutiny. Partly for these reasons we believe transfer pricing and diverted profits tax (DPT) will be key areas of dispute. They are a significant focus of this article. For the remainder we focus on VAT (and thank our colleague Lee Squires for that material).
DPT and the 12 month period
By the time of this article it will be widely understood that HMRC has issued its first DPT charging notices for the period to 31 December 2015. It seems likely that more will follow shortly: there is always a focus on yield in the lead-up to the end of HMRC’s reporting...
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