Market leading insight for tax experts
Subscribe
Home
Saved articles
Viewed articles
Login
Logout
E-newsletter
About us
Help
View online issue
BROWSE BY TOPIC
Corporate Taxes
Compliance
Corporation tax
DPT
Groups
Transactional tax
Employment taxes
Employment taxes
Termination payments
Indirect Taxes
Customs & Excise duties
Environmental taxes
IPT
VAT
International Taxes
BEPS
CFCs
Cross border
Double tax relief
Foreign profits
Residence
Transfer pricing
UK competitiveness
Withholding taxes
Private Business Taxes
OMBs
Partnerships
Private Client Taxes
CGT
IHT
Pensions & investments
Trusts & estates
Real Estate Taxes
Property taxes
REITs
Stamp Taxes
SDLT
SDRT
Tax policy & administration
Anti-avoidance
Appeals
Brexit
Compliance
HMRC Powers
Investigations
Litigation
Tax policy
Tax risk
NEWS
CASES
IN BRIEF
ANALYSIS
ONE MINUTE WITH
PEOPLE & FIRMS
TRACKERS
AUTHORS
ISSUE ARCHIVE
BROWSE BY TOPIC
Corporate taxes
Compliance
Corporation tax
DPT
Groups
Transactional tax
Employment taxes
Employment taxes
Termination payments
Indirect taxes
Customs & Excise duties
Environmental taxes
IPT
VAT
International taxes
BEPS
CFCs
Cross border
Double tax relief
Foreign profits
Residence
Transfer pricing
UK competitiveness
Withholding taxes
Private business taxes
OMBs
Partnerships
Private client taxes
CGT
IHT
Pensions & investments
Trusts & estates
Real estate taxes
Property taxes
REITs
Stamp taxes
SDLT
SDRT
Tax policy & administration
Anti-avoidance
Appeals
Brexit
Compliance
HMRC Powers
Investigations
Litigation
Tax policy
Tax risk
Subscribe
Home
Saved articles
Viewed articles
View virtual issue
View online issue
Login
Logout
E-newsletter
About us
Help
News
Cases
In brief
Analysis
One Minute With
People & Firms
Trackers
Authors
Issue Archive
SEARCH
Home
Transfer pricing
Home
Transfer pricing
TRANSFER PRICING
DPT notices and APAs: the implications of Refinitiv
Paula Ruffell
Astrid Vroom
Paula Ruffell and Astrid Vroom (
EY)
consider the implications of
Refinitiv
to transfer pricing methodologies adopted in multiple years and what this means for APAs and DPT assessments more generally.
How to handle transfer pricing discovery assessments
Joel Cooper
Paula Ruffell
Joel Cooper and Paula Ruffell (EY) outline the steps to consider if a
‘protective’ discovery assessment is issued for a transfer pricing matter.
Transfer pricing, residual profits and the cost influence curve
David Murphy
David Murphy (BSI Group) explains why, for transfer pricing purposes, the cost influence curve could be a rational starting point for contribution analysis when allocating residual profits.
The Fiat EU state aid case: swansong or phoenix reborn?
Pierre-Antoine Klethi
Peter Adriaansen
This judgment deals a blow to the European Commission’s state aid investigations concerning tax rulings on transfer pricing, writes
Pierre-Antoine Klethi and Peter Adriaansen (Loyens & Loeff).
Transfer pricing: a framework for implementing transactional profit split arrangements
Paul Sutton
Philip de Homont
Paul Sutton (LCN Legal) and Philip de Homont (Nera Economic
Consulting) set out a framework when considering the allocation of risks
in transfer pricing.
Are ‘provisions’ synonymous with ‘conditions’ in UK transfer pricing? A debate following BlackRock
Batanayi Katongera
Sarah Bond
Batanayi Katongera (in-house specialist) and Sarah Bond (Freshfields
Bruckhaus Deringer) discuss whether the UK terms should be given the
broader meaning of the OECD concepts in order to bring greater clarity
and reduce the risk of double taxation.
BlackRock: no imputation of covenants for transfer pricing purposes
Paul Sutton
The Upper Tribunal’s decision on the transfer pricing aspects of the
BlackRock
case is an overly restrictive interpretation of the law, writes Paul Sutton (LCN Legal).
Transfer pricing: new guidance on hard to value intangibles
Vladimir Milic
Anton Hume
The guidance on HTVIs is likely to have a considerable impact on the development of transfer pricing compliance, write Vladimir Milic and Anton Hume (BDO).
Transfer pricing: documentation proposals and disputes
Sarah Bond
Sarah Bond (Freshfields Bruckhaus Deringer) considers the implications for businesses of the proposed changes to required transfer pricing documentation currently under consultation.
Covid-19 and transfer pricing
Five key lessons from the OECD’s new guidance.
Go to page
of
58
EDITOR'S PICK
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
1 /7
SDLT: gardens, grounds and grazing
Max Schofield
2 /7
Much ado about non-doms: the new policy paper
Helen McGhee
,
Lynnette Bober
3 /7
A capital blow for deducting management expenses
Kyle O'Sullivan
4 /7
VAT on private school fees: 10 takeaways
Etienne Wong
5 /7
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
6 /7
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
,
Gabrielle Van der Haegen
7 /7
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
SDLT: gardens, grounds and grazing
Max Schofield
Much ado about non-doms: the new policy paper
Helen McGhee
,
Lynnette Bober
A capital blow for deducting management expenses
Kyle O'Sullivan
VAT on private school fees: 10 takeaways
Etienne Wong
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
NEWS
Read all
HMRC manual changes: 6 September 2024
Oil and gas tax changes in danger of affecting UK economic growth, says OEUK
Off-payroll working
HMRC’s position on remittances upon divorce
EU approves extension of EIS and VCT
CASES
Read all
HMRC v S&L Barnes Ltd
Bilfinger Salamis UK Ltd v HMRC
S Hackett and another v HMRC
HMRC v Labeikis and others
Other cases that caught our eye: 6 September 2024
IN BRIEF
Read all
R&D claim notification
The everyday economy
Cleaning up: tax on gifts
The end of BADR?
Lease extensions and the 3% surcharge
MOST READ
Read all
R&D claim notification
Bilfinger Salamis UK Ltd v HMRC
HMRC v Labeikis and others
Oil and gas tax changes in danger of affecting UK economic growth, says OEUK
Off-payroll working