THE KING (on the applications of) (1) REFINITIV LIMITED (2) REFINITIV UK EASTERN EUROPE LIMITED (3) LIPPER LIMITED (4) THOMSON REUTERS CORPORATION v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2023] UKUT 00257 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Michael Green & Judge Swami Raghavan on 20 October 2023
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JUDICIAL REVIEW – whether a Diverted Profits Tax notice issued to claimants (which used a “profit-split” method of arm’s length pricing), was inconsistent with an earlier Advance Pricing Agreement the claimants had entered into for Transfer Pricing purposes (which used a “cost-plus” method of arm’s length pricing) – no – claim dismissed
Published 25 October 2023