Arrival from 5:30 pm
Seminar starts 6:00 pm
Networking starts 7:00 pm

1. Credit arrangements: overview of recent trends in sub-participation, receivable financing and intermediation from a VAT angle

Credit arrangements have been the focus of courts lately. We will reflect on some of the key developments.

2. International branch structuring: latest developments for VAT and related transfer pricing / profit attribution considerations

An overview of the most recent landscape in relation to cross border intra-entity flows and whether branch planning is still a reality for VAT, and how it interplays with transfer pricing.

Arrival from 17.45
Seminar begins 18.00

1. Making Tax Digital for Corporation Tax and CT Compliance Landscape 

A brief overview of HMRC’s Making Tax Digital (MTD) initiative as it relates to Corporation Tax, including the current status and practical implications for businesses.

2. VAT Implications of Contractually Agreed Transfer Pricing Adjustments 
   A review of the recent European Court ruling in the Arcomet case, which confirms that TP adjustments stipulated in intra-group agreements may fall within the scope of VAT. Key discussion points:
   • When TP adjustments are considered remuneration for services
   • Compliance risks and VAT leakage for partially exempt businesses
   • Practical steps for reviewing TP policies and documentation
   • Insights from EU VAT Committee and national guidance

3. Transfer Pricing Implications and HMRC Nudge Letters 
   Building on the VAT discussion, this session will explore the transfer pricing consequences of intra-group services and HMRC’s recent compliance activity. Topics include:
   • HMRC’s nudge letters and focus on uncharged services
   • Risk indicators and fact patterns (e.g. centralised functions, high-cost UK roles)
   • Guidance from GfC7 and GfC13
   • Best practices for documentation, disclosure, and client engagement

4. Budget 2025 Predictions: Tax Policy and Economic Outlook 
   A forward-looking discussion on potential tax changes in the upcoming Budget