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Are ‘provisions’ synonymous with ‘conditions’ in UK transfer pricing? A debate following BlackRock

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The UK transfer pricing rules apply specifically to provisions between controlled entities, whereas the OECD rules apply to conditions. The UK legislation suggests that the UK and OECD rules should be interpreted consistently. However, while the Upper Tribunal judges in BlackRock suggest that the terms are synonymous, the outcome of the judgment arguably contradicts that view. This discussion, in the form of a written debate, considers whether the UK terms should be given the broader meaning of the OECD concepts, in order to bring greater clarity to the interpretation and application of the UK rules and reduce the risk of double taxation.

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