The transfer pricing landscape in both the UK and globally is changing. Following the publication of its final BEPS reports in 2015, the OECD has now issued a revised edition of the Transfer Pricing Guidelines, incorporating the recommendations of the BEPS project. In essence, these revisions seek to align transfer pricing outcomes with value creation through the careful analysis of cross border transactions and, critically, an accurate understanding of the conduct of counterparties. Linked to the technical changes to the transfer pricing environment is a growing requirement to understand the responses of tax authorities and how to proactively manage tax dispute resolution.
