Diane Hay, former deputy director, CT & VAT and head of the Transfer Pricing Group at HMRC tells Catherine Snowdon about some of the main difficulties she tackled while at the revenue authority and part of working party 6, offers taxpayers an insight into how transfer pricing cases are selected in the UK and talks about the future of transfer pricing.
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India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
ITR sat down for a pre-event interview with Tim Zech, WTS Germany, and Jeff Soar, WTS UK, keynote speaker at next week’s ITR AI in Tax Forum 2026 in London
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