James Anderson and Alex Rigby (Skadden) examine HMRC’s package of proposed transfer pricing reforms, and consider how they might assist with existing uncertainty and double taxation disputes.
HMRC’s consultation Reform of UK law in relation to transfer pricing permanent establishment and diverted profits tax closed for responses on 14 August 2023. As one of the three areas covered by the consultation the UK’s transfer pricing regime appears on the precipice of significant reform.
A key aim of the mooted reforms is the support of growth in the UK through the promotion of inward investment something HMRC are looking to encourage by improving tax certainty and comprehensive access to the benefits of double taxation treaties (DTTs). This article provides a review of particular aspects of the consultation regarding related party intangible transactions and DTT benefits highlighting areas HMRC has identified as creating uncertainty as...
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James Anderson and Alex Rigby (Skadden) examine HMRC’s package of proposed transfer pricing reforms, and consider how they might assist with existing uncertainty and double taxation disputes.
HMRC’s consultation Reform of UK law in relation to transfer pricing permanent establishment and diverted profits tax closed for responses on 14 August 2023. As one of the three areas covered by the consultation the UK’s transfer pricing regime appears on the precipice of significant reform.
A key aim of the mooted reforms is the support of growth in the UK through the promotion of inward investment something HMRC are looking to encourage by improving tax certainty and comprehensive access to the benefits of double taxation treaties (DTTs). This article provides a review of particular aspects of the consultation regarding related party intangible transactions and DTT benefits highlighting areas HMRC has identified as creating uncertainty as...
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