International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Feature

A revised Chapter VII signals a move away from mechanical TP approaches, stressing transaction understanding, functional analysis and context-driven documentation requirements
HMRC’s growing focus on evidencing tax decisions is shifting attention from technical accuracy to governance, requiring businesses to demonstrate how positions were reached and documented
In the second instalment of this two-part series, Jayne Stokes takes a practical approach to navigating the capital v revenue question for UK R&D claims for software development, and shares pointers for businesses
Arindam Mitra and Robin Hart examine how aggregate TP rules clash with transaction-level customs rules, creating compliance risks and requiring granular, SKU-level pricing strategies
Sponsored

Sponsored