International Aspects of The Budget

The influence of Europe looms large in this Budget. The provisions relating to domestic transfer pricing cross-border royalty payments international accounting standards (IAS) and the European Company all owe their existence to EU tax and legal developments. This is likely to be a consistent driver of changes to UK tax legislation particularly if the European Court of Justice (ECJ) continues its aggressively interventionist approach to perceived discrimination in the field of direct tax and the Commission continues to exploit the resulting uncertainty to press ahead with plans for some form of common European corporate tax system.

The introduction of transfer pricing rules between UK-resident companies owes little to logic and...