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

From:
HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
Published
25 October 2023
Category:
Tax
Release date:
20 October 2023

Read full decision in The King (oao) Refinitiv Limited and others v HMRC final decision for issue to parties and publication_

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

Updates to this page

Published 25 October 2023