Refinitiv Ltd & ors (claimants/appellants) v HM Revenue & Customs (defendant/respondent)
Tuesday 15 October 2024
By an Appellant’s Notice filed on 22 December 2023, the claimant’s appeal the decision dated 20 October 2023 of the Upper Tribunal (Tax and Chancery Chamber) dismissing the claimants’ judicial review claim regarding HMRC decision to issue Diverted Profits Tax (“DPT”) notices on the claimants in the amount of £167 million.
Issue: Whether DPT notices were lawful in circumstances where the method used for arm’s length pricing differed from that agreed by HMRC in an earlier Advance Pricing Agreement
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