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For those not already in the know, the Transfer Pricing Records Regulations (“TPRR”) released last year set a requirement that UK businesses that are part of a qualifying MNE[1] (broadly,…

There have been major reforms to the rules surrounding claims for R&D tax relief in recent years, with the most significant changes being for accounting periods beginning on or after…

The R&D advance was in the field of software/computer science/AI and the case is being held out as being of principal benefit to those companies making claims for advances in…

I’m sure Shakespeare would have admired the back-and-forth nature of the decided litigation handed down to date in the above case.  Alas (poor Yorick), for those of us who provide…

The appeal was taken by Sonder Europe Limited who acquired (via long-leases) vacant apartments from unconnected third-party landlords and then re-sold them as short-term accommodation to short-stay visitors (used for…

I’ve been always been fascinated by the difference between cakes, biscuits and confectionery and had the pleasure of being part of the team that helped Tunnocks and Lees of Scotland…

Share for share exchanges are regularly seen in various types of company sale and reorganisation transactions. Broadly, where a shareholder exchanges shares in Company A for shares in B, and…

Deeming provisions are common in tax provisions. As their names suggests, they ‘deem’ certain situations to satisfy specific conditions when they might not otherwise meet the strict wording of the…

As explained here, there has been a significant increase in recent years in individuals considering moving offshore before a business sale as non-UK residents are not subject to UK Capital…