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Home
Transfer pricing
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Transfer pricing
TRANSFER PRICING
Transfer pricing: a framework for implementing transactional profit split arrangements
Paul Sutton
Philip de Homont
Paul Sutton (LCN Legal) and Philip de Homont (Nera Economic
Consulting) set out a framework when considering the allocation of risks
in transfer pricing.
Are ‘provisions’ synonymous with ‘conditions’ in UK transfer pricing? A debate following BlackRock
Batanayi Katongera
Sarah Bond
Batanayi Katongera (in-house specialist) and Sarah Bond (Freshfields
Bruckhaus Deringer) discuss whether the UK terms should be given the
broader meaning of the OECD concepts in order to bring greater clarity
and reduce the risk of double taxation.
BlackRock: no imputation of covenants for transfer pricing purposes
Paul Sutton
The Upper Tribunal’s decision on the transfer pricing aspects of the
BlackRock
case is an overly restrictive interpretation of the law, writes Paul Sutton (LCN Legal).
Transfer pricing: new guidance on hard to value intangibles
Vladimir Milic
Anton Hume
The guidance on HTVIs is likely to have a considerable impact on the development of transfer pricing compliance, write Vladimir Milic and Anton Hume (BDO).
Transfer pricing: documentation proposals and disputes
Sarah Bond
Sarah Bond (Freshfields Bruckhaus Deringer) considers the implications for businesses of the proposed changes to required transfer pricing documentation currently under consultation.
Covid-19 and transfer pricing
Five key lessons from the OECD’s new guidance.
Transfer pricing guide to cash pooling arrangements
Daniel J. Pugh
John W. Lamszus
Selena Schneider
Selena Schneider, John W. Lamszus and Daniel J. Pugh (Crowe) provide a guide to this common treasury management tool used by multinationals to efficiently manage cash and reduce process and transaction costs.
Transfer pricing for financial transactions: what just changed?
Fan Bai
Clive Jie-A-Joen
Monique van Herksen
The OECD's new guidance marks a change in approach, as experts at Simmons & Simmons explain.
The transfer pricing of financing transactions: OECD guidance
Andrew Stewart
Anton Hume
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.
How to handle HMRC transfer pricing enquiries
Ben Henton
Paul Daly
Transfer pricing enquiries are becoming a commonplace challenge within the UK tax landscape. Paul Daly and Ben Henton (BDO) examine the practical issues.
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58
EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
HMRC manual changes: 18 July 2025
Chancellor outlines financial services strategy
CIOT reviews transfer pricing proposals
Marriage allowance: backdating claims
Further HMRC update on VAT penalties
CASES
Read all
Abbotsford Property Group Ltd and another v Revenue Scotland
R (oao Thomas Holdings Ltd and others) v HMRC
G Stenhouse and another v HMRC
Other cases that caught our eye: 18 July 2025
B D’Angelin v HMRC
IN BRIEF
Read all
HMRC’s approach to wealthy individuals
There’s only one POEM
Discovery assessments: agents
Standish v Standish
Section 899 compromise shifts international tax landscape
MOST READ
Read all
‘Legislation Day’ date announced
G Haworth and others v HMRC
One Big Beautiful Bill Act enacted
Abbotsford Property Group Ltd and another v Revenue Scotland
Wealth taxes and fiscal reality