Sam Sholli

Senior Reporter ITR

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Transfer Pricing

‘Clear limitations’: Italian advisers differ on intra-group financing TP ruling

Partners are divided on Italy vs PDM D’s analytical depth, evidentiary standards, and what the judgment signals for future intra-group financing cases

Sam Sholli, March 19 2026
Direct Tax

‘Kept the family together’: EU tax chief praises US/OECD pillar two deal

While all options presented ‘drawbacks’, European Commission tax leader Wopke Hoekstra said the controversial US carve-out deal has ‘many benefits’

Sam Sholli, March 18 2026
Direct Tax

Tax campaigners clash on pillar two as side-by-side deal costs emerge

Despite estimates that the US/OECD agreement will cost countries billions, the Fair Tax Foundation’s Paul Monaghan believes the deal is a ‘necessary evil’

Sam Sholli, March 16 2026
Direct Tax

This week in tax: HMRC defers tax agent registration for financial services businesses

The postponement came after industry representatives flagged implementation issues with the registration regime; in other news, firms made key tax partner additions

Sam Sholli, March 13 2026
Transfer Pricing

HMRC almost doubles revenue from TP cases in one year

Despite the increased yield, the time taken to resolve enquiries was at a six-year high, new HMRC statistics have revealed

Sam Sholli, March 12 2026
Direct Tax

Dan Neidle defeats £8m libel claim brought by ‘tax avoidance promoter’

The High Court’s dismissal of barrister Setu Kamal’s legal challenge represents the first successful strike-out under a new law on SLAPPs

Sam Sholli, March 11 2026