THE KING (on the applications of) (1) REFINITIV LIMITED (2) REFINITIV UK EASTERN EUROPE LIMITED (3) LIPPER LIMITED (4) THOMSON REUTERS CORPORATION v THE COMMISSIONERS FOR HIS MAJESTY鈥橲 REVENUE AND CUSTOMS [2023] UKUT 00257 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Michael Green & Judge Swami Raghavan on 20 October 2023
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JUDICIAL REVIEW 鈥� whether a Diverted Profits Tax notice issued to claimants (which used a 鈥減rofit-split鈥� method of arm鈥檚 length pricing), was inconsistent with an earlier Advance Pricing Agreement the claimants had entered into for Transfer Pricing purposes (which used a 鈥渃ost-plus鈥� method of arm鈥檚 length pricing) 鈥� no 鈥� claim dismissed
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Published 25 October 2023