Seminars

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

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 5pm
Seminar starts at 5.30pm
Networking drinks to follow

This seminar will focus on Tax Risk Management, covering:

• Tax governance and HMRC initiatives - this will also refer to FS VAT exemption rewrite (and, if time permits, a quick ‘things to note re the upcoming Pillar 2 filing’)
• HMRC’s approach on compliance
  • VAT
  • AEOI
  • HMRC evolving approach to corporate compliance with regards to Banks

Date: Wednesday 9th December 2026
Time: Registration from 5:30pm for a 6pm start, with networking from 7pm.
Location: Grant Thornton, 8 Finsbury Circus, London, EC2M 7EA

1. Cryptoasset Taxation
- Tokenisation - some of the tax barriers: international structure required, establishing substance, transfer of know-how, valuations / exit charge, and VAT complexities
- Stablecoin - current regulatory and future tax changes: tax change to treat stablecoins as Loan Relationships removes a lot of uncertainty and simplifies intra-group use of stablecoins. For GBP stablecoins the FCA is mandating that the stablecoin should be exchanged on a 1:1 parity. Previously stablecoins were near but not quite 1:1 as they are not backed 100% with a currency holding but money market funds or cash equivalent. For tax this again simplifies the position as forex gains or losses will no longer arise on stablecoin conversions.
- Crypto-Asset Reporting Framework: tokenised deposits and stablecoins, wallet and custody services, and the interaction with CRS 2.0
- CRS 2.0: enhanced due diligence and reporting requirements, and e-money products

2. Pillar Two - Lessons learned
- Data integrity and ownership: tax, legal, entity management, CoSec, finance all need to be involved, not just a tax issue
- Corporate simplifications: legacy structures should be reviewed these can add additional admin burdens or create unexpected tax charges
- CbCR: increasingly important to review by direct tax as whether UPE or local GAAP should be used as once out always out of the transitional safe harbour
- Local filings: filings multiple GIRs, QDMTT and local rules (UAE for example uses different SBIE %) increases complexity
- Expanding: many APAC jurisdictions are implementing Pillar Two, expect more registrations and more information is LATAM next?
- Timing: review process, who owns the data and signs off - this can cause a lot of delays
- Simplification for US-headed groups with the Side-by-Side rules but not until FY2026

3. Budget