Market leading insight for tax experts
View online issue

Transfer pricing briefing for August 2012

Alison Lobb and Clive Teitjen look at the recent trend for incorporating the arm's-length principle into areas of the UK corporate tax code beyond the transfer pricing rules

A recent trend is for new UK corporate tax legislation such as the patent box and new controlled foreign companies (CFC) rules to include requirements for businesses to calculate profits for specific tax purposes on an arm’s-length basis using the same principle as the one that underpins existing transfer pricing rules. There are several factors influencing this trend:

  • Essentially transfer pricing rules provide a way of separating different pools of profit for tax purposes in a structured manner;
  • Guidance on...

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:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
Top