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lthough it is generally considered that the UK’s parliament in Westminster is supreme (in that it can enact whatever provision it so wishes), there are in practice some limits on its powers.

In the base erosion and profit shifting (BEPS) action plan presented on 19 July 2013, the OECD called for the setting of transfer pricing in line with value creation (actions 8, 9 and 10) and the r

Seasoned observers of the European Court of Justice in Luxembourg point out that there was a high-water mark in deciding cases in favour of taxpayers.

The OECD’s action plan to counter base erosion and profit shifting is in full flow. BEPS may be split into three core areas: