Corporate Tax Expertise and International Structuring: Transfer Pricing, Treaties and UK CFC Rules

Advanced international corporate tax for UK tax managers and CFOs: transfer pricing under TIOPA 2010 and the OECD Guidelines, double taxation treaties and permanent establishment risk, UK CFC rules and Diverted Profits Tax, tax-neutral corporate restructurings, holding company regimes, exit taxation and the Patent Box. Grounded in HMRC guidance, TIOPA 2010, TCGA 1992, CTA 2010, and FA 2015.