TRANSFER PRICING

Anton Hume

Andrew Stewart

We are expecting new OECD guidance on the transfer pricing analysis of financing arrangements. Anton Hume and Andrew Stewart (BDO) consider what’s most likely to change.

Paul Daly

Ben Henton

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

Richard Cherrett

In 2017, the UK implemented a detailed set of ‘hybrid mismatch rules’ to combat cross-border tax advantages arising from ‘hybridity’; for example, the differing tax treatments of entities, transactions or instruments. The hybrid mismatch rules were...

Anton Hume

Is the arm’s length principle about to enfold VAT?

Anton Hume

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.

Anton Hume

Andrew Stewart

Anton Hume and Andrew Stewart (BDO) examine a range of transfer pricing financing arrangements used within groups.

Alejandro Dominguez

Pierre-Régis Dukmedjian

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

Malcolm Joy

Duncan Nott

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.

Maya Forstater

Maya Forstater (Center for Global Development) examines the accuracy of the studies claiming that addressing transfer price manipulation could generate huge sums of revenue for developing countries.

HMRC has published its transfer pricing and diverted profits tax (DPT) statistics for 2016/17 showing a massive increase in tax adjustments, report Peter Steeds & Paul Fields (KPMG).

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