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TRANSFER-PRICING


Transfer pricing enquiries are becoming a commonplace challenge within the UK tax landscape. Paul Daly and Ben Henton (BDO) examine the practical issues. 

Official statistics published this week on HMRC’s transfer pricing and diverted profits tax (DPT) activity show that HMRC’s increasing international focus has been effective in achieving its intended results. The statistics highlight the sustained increase in the risks faced by multinational corporate groups dealing with the complex and ever changing international tax environment.

Pierre-Régis Dukmedjian and Alejandro Dominguez (Simmons & Simmons) assess the EC’s ruling in the Amazon state aid case.

Malcolm Joy and Duncan Nott (BDO) explain the new requirements for the robust transfer pricing of intangible assets in the OECD’s updated transfer pricing guidelines.
 
Dinesh Yogendra and Sam Boundy (EY) set out how tax advisers should approach tax due diligence where tax insurance is used on a transaction.
 
Paul Daly (BDO) explains how a recent case has put the relationship between the two under the spotlight, with uncertain consequences for taxpayers.
 
Richard Jeens (Slaughter and May) reviews a busy year for tax disputes, both in terms of the scale and number of DPT and transfer pricing enquiries and a number of significant court decisions.
 
Philip Greenfield (PwC) reports on the extent to which countries have started to adopt the BEPS recommendations. 
 
Tim Sarson (KPMG) reviews the latest developments in the international tax world.
 
Tim Sarson (KPMG) reviews the latest developments in the international tax world.
 
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