2010 represents a landmark year for international transfer pricing, with the OECD undertaking a fundamental overhaul of its Transfer Pricing Guidelines as well as initiating a major review of the transfer pricing of intangibles, an area which has been highlighted as a primary concern for taxpayers and authorities alike. In the UK and across the EU a number of welcome developments in relation to practical application and administration of transfer pricing have resulted in clearer guidance for UK taxpayers in relation to APAs, thin capitalisation issues and inter-company services.
