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HMRC Transfer Pricing Victory

Murray Clayson tax partner at Freshfields Bruckhaus Deringer LLP comments on the landmark Special Commissioners' decision in the DSG Retail transfer pricing case
It is commonly said that international transfer pricing is the tax topic of most significant concern to multinational businesses. It is perhaps surprising therefore that it has taken until now (minor skirmishes aside) to produce any very significant UK transfer pricing case law.
The UK became nervous of transfer pricing a century or so ago particularly in view of the extensive colonial and other overseas operations that this island trading nation had established across the world at the height of Empire. An early legislative response was Finance (No 2) Act 1915 s 31(3):
'Where a non-resident person not being a British...

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