Jon Hills on establishing whether a company is small, medium or large for the purposes of the UK transfer pricing rules.
Question: I am trying to establish whether my client company A is small medium or large for the purposes of the UK transfer pricing rules. It has two subsidiaries B and C. It holds 75% of the issued share capital and voting rights in both companies. Company B also has a 38% stake in company D. Company A also a 30% stake in company E which in turn has a 28% stake in company F. In applying the financial and headcount tests to company A which companies’ figures should I include and how much of each?
Answer: Although the 2003 EC recommendation...
