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Transfer pricing

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Latest Tax News

SDLT—no MDR for land with planning permission (Ladson Preston and AKA Developments v HMRC)

SDLT—no MDR for land with planning permission (Ladson Preston and AKA Developments v HMRC)

The following Private Client news provides comprehensive and up to date legal information on SDLT—no MDR for land with planning permission (Ladson Preston and AKA Developments v HMRC)

Tax weekly highlights—22 July 2021

Tax weekly highlights—22 July 2021

The following Tax news provides comprehensive and up to date legal information on Tax weekly highlights—22 July 2021

Bonus payments received by LLP members were earnings from previous employment (Charles Tyrwhitt LLP v HMRC)

Bonus payments received by LLP members were earnings from previous employment (Charles Tyrwhitt LLP v HMRC)

The following Tax news provides comprehensive and up to date legal information on Bonus payments received by LLP members were earnings from previous employment (Charles Tyrwhitt LLP v HMRC)

Court of Appeal rules that third-party loan servicing is liable to VAT (Target Group Ltd v HMRC)

Court of Appeal rules that third-party loan servicing is liable to VAT (Target Group Ltd v HMRC)

The following Tax news provides comprehensive and up to date legal information on Court of Appeal rules that third-party loan servicing is liable to VAT (Target Group Ltd v HMRC)

Featured Tax content

VAT definition

VAT definition

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VAT—what is a transfer of a business as a going concern?

VAT—what is a transfer of a business as a going concern?

VAT—what is a transfer of a business as a going concern?IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...

SDLT—deeds of rectification

SDLT—deeds of rectification

SDLT—deeds of rectificationStamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from...

What is an intangible fixed asset?

What is an intangible fixed asset?

What is an intangible fixed asset?Part 8 of the Corporation Tax Act 2009 (CTA 2009) is a specific corporation tax regime that applies exclusively to...

Practice notes

VAT treatment of damages and compensation payments

VAT treatment of damages and compensation paymentsFORTHCOMING CHANGE: HMRC is in the process of revising Revenue and Customs Brief 12 (2020) on the...
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19th May
tag iconIn-house
Practice notes

Amortisation of intangible fixed assets

Amortisation of intangible fixed assetsWhere a company acquires (or otherwise incurs capitalised expenditure upon) an intangible fixed asset that...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes

EIS—deferred gain becomes chargeable to CGT

EIS—deferred gain becomes chargeable to CGTCoronavirus (COVID-19): In response to the coronavirus (COVID-19) pandemic, the government introduced a...
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19th May
Practice notes

Property holding structures—SDLT and VAT treatment of a Jersey Property Unit Trust (JPUT)

Property holding structures—SDLT and VAT treatment of a Jersey Property Unit Trust (JPUT)IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the...
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19th May
Practice notes

Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)

Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)STOP PRESS relating to property rich collective investment...
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19th May
Practice notes

Commercial service charges—VAT implications

Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
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Produced in partnership with Martin Scammell 19th May
Practice notes

Offshore receipts in respect of intangible property (ORIP)

Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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19th May
Practice notes

FATCA in the UK—the UK:US Intergovernmental Agreement: an outline

FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
tag iconIn-house
Practice notes

Tax considerations on a loan agreement—the tax gross up clause

Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
Precedents

Clause—tax gross up—commercial agreements

1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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19th May
Practice notes

Section 198 and 199 elections on transactions involving real estate

Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 19th May
Practice notes

Taxation of UK LLPs

Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
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19th May
Practice notes

Capital reduction demergers

Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
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Produced in partnership with Zoe Feller of Bird & Bird 19th May
Q&As

Corporate redomiciliation—can a non-UK company redomicile into the UK?

Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
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19th May
Practice notes

Transfer of a trade under common ownership

Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
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19th May
Practice notes

SDLT group relief

SDLT group reliefFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports, the government announced...
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19th May

Most recent Transfer pricing content

Practice notes

What is transfer pricing?

What is transfer pricing?Transfer pricing is a concept that refers to the pricing of goods, services, funds and tangible and intangible assets...
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Produced in partnership with Simon Gough and Caroline Brown of Bird & Bird LLP 21st Jul
Practice notes

Transfer pricing of loans and guarantees

Transfer pricing of loans and guaranteesApplication of UK’s transfer pricing rules to loansUK legislation includes transfer pricing rules, which...
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Produced in partnership with Andréa Leho of Macfarlanes 15th Jul
Practice notes

Characterisation of entities for transfer pricing purposes

Characterisation of entities for transfer pricing purposesFunctional analysisA key component of the arm's length principle is the requirement to...
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Produced in partnership with Robert Langston of Saffery Champness 30th Jun
Practice notes

Transfer pricing and private equity transactions

Transfer pricing and private equity transactionsIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Batanayi Katongera of Macintyre Hudson 30th Jun
Practice notes

Establishing an arm's length price for transfer pricing purposes

Establishing an arm's length price for transfer pricing purposesArm's length principleThe arm’s length principle is endorsed by the OECD (Organisation...
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Produced in partnership with Joel Cooper, Rachit Agarwal and James Dalley of DLA Piper 24th Jun
Practice notes

When is the UK participation condition met?

When is the UK participation condition met?IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation...
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Produced in partnership with Robert Langston of Saffery Champness 24th Jun
Practice notes

What happens when the transfer pricing rules apply?

What happens when the transfer pricing rules apply?IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Joel Cooper, Rachit Agarwal and James Dalley of DLA Piper 24th Jun
Q&As

Does a connected entity as defined in section 1122 of the Corporation Tax Act 2010 (CTA 2010) or an associated company with the meaning of section 449 of the CTA 2010 apply if the entity is offshore?

Does a connected entity as defined in section 1122 of the Corporation Tax Act 2010 (CTA 2010) or an associated company with the meaning of section 449...
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23rd Jun
Q&As

Which types of persons are within the UK transfer pricing regime?

Which types of persons are within the UK transfer pricing regime?The UK’s transfer pricing regime applies to ‘persons’ and therefore includes...
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23rd Jun
Practice notes

When do the UK transfer pricing rules apply?

When do the UK transfer pricing rules apply?IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation...
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Produced in partnership with Simon Gough and Caroline Brown of Bird & Bird LLP 23rd Jun
Q&As

Does the UK (or HMRC in practice) express a preference for a particular transfer pricing method for establishing an arm’s length price of interest, which is based on the location of the lender and the borrower?

Does the UK (or HMRC in practice) express a preference for a particular transfer pricing method for establishing an arm’s length price of interest,...
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5th Jun
Q&As

What method will HMRC use when determining an arm's length interest rate on a related party loan?

What method will HMRC use when determining an arm's length interest rate on a related party loan?In this Q&A we have assumed that the lending in...
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5th Jun
Practice notes

Transfer pricing and joint ventures

Transfer pricing and joint venturesThis Practice Note considers the UK tax aspects of the application of the UK’s transfer pricing rules to joint...
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Produced in partnership with Simon Gough and Caroline Brown of Bird & Bird LLP 5th Jun

Popular documents

Summary assessment—statement of costs

Summary assessment—statement of costs

Summary assessment—statement of costsSummary assessment is the procedure whereby costs are assessed by the judge who has heard the case or application (see Practice Note: Summary assessment). This Practice Note considers the use of a statement of costs in summary assessment. Form N260 is a model

Reversionary lease by reference

Reversionary lease by reference

 LR1. Date of the lease[date]LR2. Title Number(s)LR2.1 Landlord's title number(s)[title numbers out of which this Lease is granted. Leave blank if not registered]LR2.2 Other title numbers[existing title number(s) against which entries of matters referred to in LR9, LR10, LR11 and LR13 are to be

Arms length management organisations (ALMOs)

Arms length management organisations (ALMOs)

Arms length management organisations (ALMOs)An arms length management organisation (ALMO) is a not-for-profit company that provides housing services on behalf of a local housing authority (LHA). Usually an ALMO is set up by the LHA to manage and improve all or part of its housing stock with the LHA

Enforcing a warrant of control

Enforcing a warrant of control

Enforcing a warrant of controlThis Practice Note has been produced by enforcement specialists, The Sheriffs Office. It guides users through the process of enforcing a warrant of control obtained from the County Court as a method of enforcing a money judgment; whereby the judgment creditor takes