Tax News: February 2024

In this podcast, Zoe Andrews and Tanja Velling discuss two First-tier Tribunal decisions. One is a fun case and they’ve set this up a mystery to be solved in the first few minutes of the podcast. The other FTT decision is Bolt Services on the VAT treatment of taxi rides booked through a ride-hailing app. 

The podcast also covers the Court of Appeal’s decision in Dolphin Drilling considering the meaning of the word “incidental”; the immediate context for the decision is the hire cap under the oil contractors’ regime, but the decision may have implications in other tax contexts, such as for determining whether something is a “main purpose” for the unallowable purpose test in the loan relationships regime. 

Zoe and Tanja further discuss new HMRC guidance on transfer pricing, the summary of responses to HMRC’s consultation on reforming transfer pricing, permanent establishments and Diverted Profits Tax legislation and HMRC’s latest transfer pricing and DPT statistics, as well as the OECD’s ICAP statistics and Pillar 2 impact assessment.