TRANSFER PRICING

Gary Barnett

VAT developments concerning transfer pricing adjustments, tripartite arrangements and the Tour Operators Margin Scheme are examined in this month’s review by Jo Crookshank and Gary Barnett (Simmons & Simmons).

Phil Maggs

Phil Sneade

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.

Simon Wood

HMRC are clearly not happy with the standard of analysis and documentation that they are currently seeing, writes Simon Wood (BDO).

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.

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.

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.

Peter Adriaansen

Pierre-Antoine Klethi

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).

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.

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.

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).

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