5/2/2025 2:19:03 PM Transfer pricing, permanent establishment and diverted profits tax reform – draft legislation By Alex Sim Gianni Prenol As we previously reported, on 28 April 2025 the UK government announced a technical consultation on draft legislation (the Draft...
4/28/2025 3:58:18 PM UK tax changes on the horizon By Tanja Velling How foolish I was for thinking that occasions such as an Autumn Budget or Spring Statement would no longer be followed by a “tax...
12/18/2024 10:36:25 AM Balancing growth and taxes: the UK government's corporate tax roadmap By Tanja Velling The announcement of a Spring Statement (rather than another Budget) on 26 March 2025 chimes with the promise of “predictability,...
11/25/2024 10:13:16 AM How do you value an APA after the Court of Appeal's decision in Refinitiv? By Mike Lane Transfer pricing experts are used to grappling with some tricky valuation questions when it comes to intellectual property rights. After...
11/22/2024 10:45:40 AM Who has won the MAP awards? By Tanja Velling Dispute prevention and resolution is a key theme of the OECD’s annual “Tax Certainty Day”. The 2024 edition took place in Athens on 15...
10/10/2024 3:21:43 PM HMRC’s “known position” on transfer pricing compliance By Zoe Andrews HMRC’s Transfer Pricing Guidelines for Compliance (GfC7) are promoted as “best practice approaches to transfer pricing to lower risk and...
5/28/2024 11:22:46 AM Tax Disputes Podcast: France By Zoe Andrews I’m sad to say we have reached the end of our round the world Tax Disputes podcast series but we are going out in style with a trip to...
4/23/2024 9:20:06 AM Firm Foundations: Taking Stock of BlackRock By Slaughter and May In the spirit of adventure, or my sapless version of it, I asked ChatGPT 3.5 to propose some puns to deploy in the title of this post....
1/17/2024 5:10:35 PM The DPT is dead; long live the DPT! By Slaughter and May Having introduced more than twenty brand-new taxes since the turn of the millennium — at a rate of roughly one new tax per year — did the...
6/26/2023 1:08:53 PM New Brazilian Transfer Pricing Framework: moving towards the OECD standard By Dante Zanotti Arthur Almeida Law No. 14,596 aligns the Brazilian transfer pricing rules with the standards embodied by the OECD Transfer Pricing Guidelines and...
6/23/2023 9:31:48 AM Transfer pricing, permanent establishment and diverted profits tax reform By Tanja Velling The changes proposed by the UK government in its consultation on the reform of the transfer pricing, permanent establishment and diverted...
11/11/2022 11:56:27 AM Transfer pricing and EU State aid – CJEU reaffirms national tax autonomy and annuls Commission’s decision in Fiat case By Zoe Andrews Where should the line be drawn between the prohibition on State aid and Member States’ fiscal autonomy? According to the Commission and...
7/29/2022 9:59:42 AM BlackRock revisited: what is the purpose of the “unallowable purpose” rule? By Slaughter and May That might sound like a strange question, but it lurks just beneath the surface of the Upper Tribunal’s keenly-awaited decision in...
4/19/2022 10:24:38 AM It's not TP bein' green By Slaughter and May As Kermit (and others, more recently) famously sung, "It's not easy bein' green; it seems you blend in with so many other ordinary...
1/11/2022 1:32:25 PM Finland amends its transfer pricing rules – long-awaited improvement or a new begin for transfer pricing disputes? By Einari Karhu Finland has amended its transfer pricing rules as of January 2022 enabling the Finnish Tax Administration (FTA) to make transfer pricing...
4/7/2021 10:24:18 AM The Netherlands proposes new legislation to deal with asymmetrical transfer pricing adjustments By Paul Sleurink On 4 March 2021, the Dutch government presented a draft bill for comments by interested parties introducing fundamental changes to Dutch...