After trying to fight a whopping £167m tax bill, a court sided with the tax agency against a former Thomson Reuters business.
An entity of the London Stock Exchange Group (LSEG) faced a hefty tax bill after a blockbuster deal which saw it buy a data company from Swiss-based Thomson Reuters for $27bn (£19.3bn) in 2019.
Previously known as Refintiv, the data unit’s name was changed to LSEG Data & Analytics.
HMRC slapped a £167m tax bill against the LSEG unit after it decided to issue diverted profits tax (DPT) notices.
The DPT regime was introduced in 2015 to address the situation where multi-national groups deploy arrangements to divert profits away from the UK to lower tax jurisdictions.
The LSEG unit filed a judicial review claim against the tax authority’s tax bill, arguing that the DPT notices were unlawful in public law terms.
However, last October, the Upper Tax Tribunal ultimately dismissed LSEG case. The legal challenge was taken to the Court of Appeal last month.
However, Lord Justice Underhill, Lady Justice Whipple and Sir Launcelot Henderson dismissed the appeal, ruling there is no objection in public law to the relevant assessments to DPT raised by HMRC.
The only step left for LSEG will be to try and bring its case to the Supreme Court, but it is yet unclear if it’ll consider that final step in its fight against this tax bill.
The tax agency and Thomson Reuters were approached for comment.