John Hobster, Head of Global Accounts in Ernst & Young's Global Transfer Pricing Team, introduces this special Tax Journal issue focussing on transfer pricing
Waseem Khokhar, Associate with DLA Piper's Tax Investigations and Disputes Group, comments on the recent Opinion of Advocate-General Geelhoed concerning the Thin Cap GLO
Mark Schofield, Tax Partner, and Eric Peden, Tax Senior Manager, both of PricewaterhouseCoopers LLP in London discuss limitation on benefits and treaty qualification rules under the UK/US tax treaty
Anneli Collins, UK Tax Partner, and Jim Sams, US Seconded Partner, KPMG in the UK, highlight some of the principal issues faced by a UK group doing deals in the US
Roopa Aitken, international tax director, and Danny Beeton, head of transfer pricing at Grant Thornton, discuss the tax and transfer pricing considerations for companies expanding overseas
Anneli Collins and Michael Bird of KPMG's International Corporate Tax group discuss their experience to date in applying for clearances under the new arbitrage rules
Sara Luder of Slaughter and May looks at the new tax arbitrage rules in Finance (No. 2) Act 2005
Simon Whitehead, partner, Dorsey & Whitney, discusses the pending European cases involving the tax treatment of transactions with companies with their seat outside the EU
In the light of the recent Marks & Spencer case, John Cullinane, Tax Partner at Deloitte, offers an alternative way forward