This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) covers the decisions in Refinitiv, Syngenta and Cobalt and HMRC’s updated guidance on share exchanges.
Refinitiv: JR challenge to DPT notice
The Court of Appeal in Refinitiv Ltd and others v HMRC [2024] EWCA Civ 1412 dismissed the taxpayer’s judicial review claim seeking to quash or declare unlawful a diverted profits tax (DPT) notice. Refinitiv a UK resident company in the Thomson Reuters group had argued that the DPT notice issued by HMRC in 2018 was incompatible with an advance pricing agreement (APA) entered into for the period from 2008 to 2014. The keen-eyed reader will spot that this APA had been agreed before DPT was enacted and indeed at the time of negotiating the APA it was not even contemplated.
The purpose of an APA is to determine a method for resolving transfer pricing...
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This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) covers the decisions in Refinitiv, Syngenta and Cobalt and HMRC’s updated guidance on share exchanges.
Refinitiv: JR challenge to DPT notice
The Court of Appeal in Refinitiv Ltd and others v HMRC [2024] EWCA Civ 1412 dismissed the taxpayer’s judicial review claim seeking to quash or declare unlawful a diverted profits tax (DPT) notice. Refinitiv a UK resident company in the Thomson Reuters group had argued that the DPT notice issued by HMRC in 2018 was incompatible with an advance pricing agreement (APA) entered into for the period from 2008 to 2014. The keen-eyed reader will spot that this APA had been agreed before DPT was enacted and indeed at the time of negotiating the APA it was not even contemplated.
The purpose of an APA is to determine a method for resolving transfer pricing...
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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