John Lindsay Linklaters highlights a new pitfall which has arisen as a result of the extension of the scope of UK transfer pricing legislation to transactions between UK-resident companies
This article highlights a new pitfall for the unwary where an inter-company foreign currency loan is used to enable the borrower to obtain the benefit of matching treatment and the borrower could not have borrowed the amount in question were it dealing at arm's length.
From 1 April 2004 the scope of UK transfer pricing legislation was extended to transactions between UK-resident companies. As a result a tax asymmetry can arise where a UK group of companies prepares its accounts in sterling and one UK-resident company within the group makes a foreign currency loan to another UK-resident group company (matching company) in...
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John Lindsay Linklaters highlights a new pitfall which has arisen as a result of the extension of the scope of UK transfer pricing legislation to transactions between UK-resident companies
This article highlights a new pitfall for the unwary where an inter-company foreign currency loan is used to enable the borrower to obtain the benefit of matching treatment and the borrower could not have borrowed the amount in question were it dealing at arm's length.
From 1 April 2004 the scope of UK transfer pricing legislation was extended to transactions between UK-resident companies. As a result a tax asymmetry can arise where a UK group of companies prepares its accounts in sterling and one UK-resident company within the group makes a foreign currency loan to another UK-resident group company (matching company) in...
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:
