Back in 2015, my first ever blog asked Does the UK Diverted Profits Tax help or hurt BEPS? Whatever the answer, the level of complexity and the challenges it brought to UK cross-border taxation cannot be underestimated. The recent decision of the UK Upper Tribunal in in Refinitiv Ltd and others v HM Revenue &…

Bram Markey – EMEA Leader Tax Controversy & Dispute Resolution at PwC Belgium Raphaël Devroye – Transfer Pricing Manager at PwC Belgium In a recent judgement[1], the Belgian Court of Appeal of Ghent ruled in favour of the taxpayer as regards a transfer pricing case in relation to intangibles. Even though the case is complex…