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TRANSFER PRICING


Tax officials from 90 countries have agreed on the need to simplify transfer pricing rules and make them ‘more robust’.

Companies should pay a fair rate of tax and ‘move vigorously towards the path of transparency’, the Labour peer and former newspaper publisher Lord Hollick told tax experts earlier this month, as campaigners renewed calls for country by country reporting (CBCR) by multinationals and claimed that

HMRC figures show that significant progress has been made in resolving transfer pricing issues with companies since a new approach was adopted in 2008, the department announced.

A country-by-country guide to some of the key tax developments in 2011

Ken Almand reviews the top developments in 2011 affecting transfer pricing

Multinational ‘tax dodges’ are estimated to account for over half of all illicit capital flight from developing countries, the European Network on Debt and Development (Eurodad), a network of NGOs from 19 European countries, has claimed.

Card image Judith Knott Ian Brimicombe John Overs Tim Voak Mark Edwards

Five leading tax professionals, including HMRC's Judith Knott, took part in a roundtable discussion on UK tax competitiveness. Much of the discussion, chaired by John Overs, concerned CFC reform and the potential ‘gateway’ test to filter cases out of the regime.

Sarah Norton summarises the changes regarding real-time working of transfer pricing issues and Advanced Pricing Agreements, cost contribution agreements and share options

Robert Langston outlines how commissionaire structures operate and the resulting tax risks following the Dell and Zimmer cases.

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