Transfer pricing enquiries are becoming a commonplace challenge within the UK tax landscape. Paul Daly and Ben Henton (BDO) examine the practical issues.
The context
The rapidly changing international tax environment is increasing the risk of tax disputes and in particular transfer pricing (TP) enquiries. The UK like many other jurisdictions has introduced a raft of rule changes following the base erosion and profit shifting (BEPS) project recommendations made by the OECD and TP has been an important focus. The BEPS project and the OECD recommendations resulted in a raising of the bar for documentation and compliance standards alongside a more detailed analytical framework to enable the alignment of taxable profit with value creation across a group.
In response to these changes the approach in the UK (and many tax authorities globally) has focused on a range of measures to combat perceived BEPS. The...
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Transfer pricing enquiries are becoming a commonplace challenge within the UK tax landscape. Paul Daly and Ben Henton (BDO) examine the practical issues.
The context
The rapidly changing international tax environment is increasing the risk of tax disputes and in particular transfer pricing (TP) enquiries. The UK like many other jurisdictions has introduced a raft of rule changes following the base erosion and profit shifting (BEPS) project recommendations made by the OECD and TP has been an important focus. The BEPS project and the OECD recommendations resulted in a raising of the bar for documentation and compliance standards alongside a more detailed analytical framework to enable the alignment of taxable profit with value creation across a group.
In response to these changes the approach in the UK (and many tax authorities globally) has focused on a range of measures to combat perceived BEPS. The...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
