John Henshall and Miles Unwin Partner and Senior Manager with Deloitte consider whether UK transfer pricing legislation can apply to transactions between two companies with common shareholders
This article considers the issue of whether UK transfer pricing legislation can apply to transactions between two companies each of which is controlled by the same body of investors but neither of which is controlled by a single person. The shareholding outlined in Figure 1 for Cordial Ltd and Squash Ltd illustrates the problem. All statutory references are to ICTA 1988 unless otherwise stated.
We contend that the transfer pricing legislation both pre-corporation tax self-assessment (s 770) and post-corporation tax self-assessment (Sch 28AA) is inapplicable to a transaction between Cordial and Squash. This is because no one person has direct...
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John Henshall and Miles Unwin Partner and Senior Manager with Deloitte consider whether UK transfer pricing legislation can apply to transactions between two companies with common shareholders
This article considers the issue of whether UK transfer pricing legislation can apply to transactions between two companies each of which is controlled by the same body of investors but neither of which is controlled by a single person. The shareholding outlined in Figure 1 for Cordial Ltd and Squash Ltd illustrates the problem. All statutory references are to ICTA 1988 unless otherwise stated.
We contend that the transfer pricing legislation both pre-corporation tax self-assessment (s 770) and post-corporation tax self-assessment (Sch 28AA) is inapplicable to a transaction between Cordial and Squash. This is because no one person has direct...
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:
