TRANSFER-PRICING

Phil Maggs

Phil Maggs and Phil Sneade (Frontier Economics) explain why it is usually wrong to argue for a ‘risk-free’ return for capital at arm’s length.

Robert Langston

Robert Langston (Saffery) explains why it is necessary to consider international tax principles, such as entity classification and transfer pricing, alongside the disguised investment management fee rules.

Sarah Bond

Helen Buchanan

The Court of Appeal judgment restores order, write Sarah Bond and Helen Buchanan (Freshfields Bruckhaus Deringer).

Robert Langston

Robert Langston (Saffery) provides a practical case study on the operation of the corporate interest restriction where related party guarantees and withholding tax issues are involved.

Court of Appeal overturns Upper Tribunal decision on transfer pricing but upholds conclusion on unallowable purpose.

Phil Roper

Charles Havisham

The thrust of HMRC’s guidance is to reject the notion that a profit split shouldn’t be used to reward risk control contributions, write Phil Roper and Charles Havisham (KPMG).

Mike Lane

Zoe Andrews

The Court of Appeal’s decision in Dolphin Drilling and consultation responses on the modernisation of transfer pricing, DPT and PEs are among the recent developments in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).

Stephen Daly

It is highly unlikely that the CJEU will follow Advocate General Pitruzzella’s opinion in the Apple state aid case, writes Stephen Daly (King’s College London).

Alex Rigby

James Anderson

James Anderson and Alex Rigby (Skadden) examine HMRC’s package of proposed transfer pricing reforms, and consider how they might assist with existing uncertainty and double taxation disputes.

Tim Sarson

The international tax world is still dominated by BEPS 2.0 developments, reports Tim Sarson (KPMG). This article includes an update on the national implementation of Pillar Two.

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