Tax - Transfer Pricing

Recent Articles

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  01/07/2025

  United Kingdom

  UK Tax Disputes Digest (Summer 2025)

  Welcome to the summer 2025 edition of our UK Tax Disputes Digest: a high-level summary of key developments in contentious tax over the last few months for tax and legal in-house professionals.As with previous editions, we have seen a continued increase in HMRC activity across various areas. Both individual and corporate taxpayers would be well-advised to check their tax position as soon as possible to prepare for any potential HMRC investigation into their tax affairs.In this edition, we look at just a few of these developments, including the latest in relation to the challenges and opportunities...

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  15/04/2025

  United Kingdom

  Good news for taxpayers in relation to claims for overpaid tax: Christian Peter Candy v HMRC [2025] UKFTT 00416 (TC)

  IntroductionAn interesting procedural decision has been released in relation to overpayment relief claims. Although the appeal concerns a claim for repayment of stamp duty land tax (“SDLT”), it should be of wider interest. The decision confirms that overpayment relief claims are intended to provide a final statutory remedy where other remedies have been exhausted. This will be positive news for taxpayers looking to make claims for overpaid tax.BackgroundMr Candy had an initial liability to SDLT (in the sum of £1,920,000) triggered by substantial performance of a contracted-out...

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  08/04/2025

  United Kingdom

  UK Tax Disputes Digest (Spring 2025)

  Welcome to the spring 2025 edition of our UK Tax Disputes Digest: a high-level summary of key developments in contentious tax over the last few months for tax and legal in-house professionals.As with previous editions, we have seen a continued increase in HMRC activity across various areas. Both individual and corporate taxpayers would be well-advised to check their tax position as soon as possible to prepare for any potential HMRC investigation into their tax affairs.In this edition, we look at just a few of these developments, including the latest in relation to BEPS Pillar Two and potential...

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  26/03/2025

  United Kingdom

  Spring Statement 2025 – key tax announcements

  The Chancellor delivered the Spring Statement today, as planned. The Spring Statement speech was relatively short compared to those delivered at prior fiscal events, finishing in just over half an hour. In line with recent press speculation and statements from members of government, today’s Spring Statement was not a budget nor an “emergency budget”, with its primary focus remaining on spending.However, whilst it was confirmed early on in the speech that no tax increasing measures would be announced, a number of tax-related documents have subsequently been released. Primarily,...

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  15/01/2025

  China

  2025 – Topics that may Concern You

  Companies doing business in China constantly have to deal with changes in regulations and new laws. This will also continue in 2025.Topics such as the new PRC Company Law, new PRC Tariff Law, PRC Regulations on Export Control of Dual-Use Items, network data security management, data transfer, opening up capital markets to foreign investment, and raise of statutory retirement age of employees etc. will continue to be a concern for many companies in China in 2025.Complying with regulatory requirements is one of the key challenges for foreign companies and investors in China, not only in terms of...

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  12/12/2024

  United Kingdom

  UK Tax Disputes Digest (Winter 2024)

  Welcome to the Winter 2024 edition of our UK Tax Disputes Digest: a high-level summary of key developments in contentious tax over the last few months for heads of tax, finance directors, general counsel and other in-house professionals.As with previous editions, we have seen a continued increase in HMRC activity across various areas. Both individual and corporate taxpayers would be well-advised to check their tax position as soon as possible to prepare for any potential HMRC investigation into their tax affairs.In this edition, we look at just a few of these developments, including in relation...

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