The CIOT has responded to HMRC’s consultation Transfer pricing: scope and documentation. (This was separate to the related consultation Reform of transfer pricing permanent establishment and diverted profits tax highlighted in last week’s news.)
The scoping consultation covered the following two transfer pricing-related proposals which HMRC said were aimed at protecting the UK’s tax base:
amendment to the exemption for SMEs; and
introduction of a requirement for multinationals to report information on cross-border related-party transactions to HMRC.
The CIOT has raised several key points including:
broad agreement with the removal of the exemption for medium-sized businesses for transfer pricing purposes accepting that the change will be mitigated by the introduction of the new general exemption for UK-to-UK transactions. Alongside that change the Institute suggests raising the proposed small business exemption threshold from £10m to at least £15–20m to ensure that the...
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The CIOT has responded to HMRC’s consultation Transfer pricing: scope and documentation. (This was separate to the related consultation Reform of transfer pricing permanent establishment and diverted profits tax highlighted in last week’s news.)
The scoping consultation covered the following two transfer pricing-related proposals which HMRC said were aimed at protecting the UK’s tax base:
amendment to the exemption for SMEs; and
introduction of a requirement for multinationals to report information on cross-border related-party transactions to HMRC.
The CIOT has raised several key points including:
broad agreement with the removal of the exemption for medium-sized businesses for transfer pricing purposes accepting that the change will be mitigated by the introduction of the new general exemption for UK-to-UK transactions. Alongside that change the Institute suggests raising the proposed small business exemption threshold from £10m to at least £15–20m to ensure that the...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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