Chas North KPMG Global Transfer Pricing Services tax partner and Neil Kelly tax manager KPMG consider the guidance on transfer pricing contained in the Inland Revenue's recently-published International Manual
The Inland Revenue has recently published the International Manual (the manual). This article explores the approach suggested for inspectors in selecting working and concluding transfer pricing enquiries to encourage companies to judge their transfer pricing policies using the same criteria as the Inland Revenue will use.
The manual represents the first major statement from the Inland Revenue on its approach to transfer pricing work. It does more than simply bring into one place more limited guidance in other manuals and Tax Bulletins. The present transfer pricing legislation has been effective since 1999 and the introduction...
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Chas North KPMG Global Transfer Pricing Services tax partner and Neil Kelly tax manager KPMG consider the guidance on transfer pricing contained in the Inland Revenue's recently-published International Manual
The Inland Revenue has recently published the International Manual (the manual). This article explores the approach suggested for inspectors in selecting working and concluding transfer pricing enquiries to encourage companies to judge their transfer pricing policies using the same criteria as the Inland Revenue will use.
The manual represents the first major statement from the Inland Revenue on its approach to transfer pricing work. It does more than simply bring into one place more limited guidance in other manuals and Tax Bulletins. The present transfer pricing legislation has been effective since 1999 and the introduction...
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:
