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2010 review: transfer pricing

The top 5 developments by Nick Foster-Taylor

Five key developments in 2010 affecting transfer pricing were as follows:

1. 2010 update to OECD Transfer Pricing Guidelines

In July 2010 the OECD released a long-awaited update to Transfer Pricing Guidelines for Multinational Enterprises (MNEs) incorporating major revisions to Chapters I to III and a new Chapter IX ‘Transfer Pricing Aspects of Business Restructurings’. This represents the most significant wholesale modification to the Guidelines since their introduction in 1995. Draft clauses for the 2011 Finance Bill issued by HMRC confirm that these guidelines will be the new reference basis for UK multinationals for accounting periods beginning after 1 April 2011.

Why it matters: This definitive guide to international transfer pricing now contains a number of updates to reflect changing audit and business practices worldwide. Most notably the strict hierarchy of selection of pricing methods has been substantially revised – previously...

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