The UK is becoming an increasingly competitive place to conduct research and/or hold intellectual property (IP). Lorna Smith, Matthew Dixon and Nicola Bellamy of Grant Thornton go through the changes to the UK tax system over a number of years, such as the extension of R&D reliefs and the introduction of the patent box regime, and their impact on transfer pricing.
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While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems