Transfer pricing
Knowing when to stop may be ‘the big question’ in transfer pricing, says OECD
Transfer pricing risks are among the largest tax risks that tax administrations face, but rates of tax recovery resulting from…23 Jan 2012
HMRC marks ‘significant progress’ in resolving transfer pricing issues
HMRC figures show that significant progress has been made in resolving transfer pricing issues with companies since a new approach…11 Jan 2012
2011 international review
A country-by-country guide to some of the key tax developments in 201115 Dec 2011
2011 review: transfer pricing
Ken Almand reviews the top developments in 2011 affecting transfer pricing15 Dec 2011
Eurodad steps up campaign for country-by-country reporting
Multinational ‘tax dodges’ are estimated to account for over half of all illicit capital flight from developing countries, the European…29 Nov 2011
Roundtable discussion: tax competitiveness and CFC reform
Five leading tax professionals, including HMRC's Judith Knott, took part in a roundtable discussion on UK tax competitiveness. Much of the discussion, chaired by John Overs, concerned CFC reform and the potential ‘gateway’ test to filter cases out of the regime.11 Nov 2011
Updates to HMRC's International Manual
Sarah Norton summarises the changes regarding real-time working of transfer pricing issues and Advanced Pricing Agreements, cost contribution agreements and share options27 Oct 2011
Practice guide: handling commissionaire structures
Robert Langston outlines how commissionaire structures operate and the resulting tax risks following the Dell and Zimmer cases.20 Oct 2011
Ask an expert: resolving tax disputes
James Bullock explains the best course of action for resolving a tax dispute6 Oct 2011
Tax and development: PwC and EC officials defend transfer pricing report
PwC has been forced to defend a report prepared for the European Commission after critics claimed that it was ‘strongly…17 Aug 2011
Tax and development: transparency report discounts multinationals’ tax planning
The objective of holding multinationals to account in relation to tax planning strategies – one of six stated ‘possible objectives’…27 Jul 2011
Tax on the life of guarantees
Bank loans to corporate borrowers are often supported by guarantees from related companies. Lydia Challen and Tim Harrop identify the principal tax issues on the provision of such a guarantee, from its creation to its termination30 Jun 2011
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