On 26 May 2016, HMRC released a consultation paper entitled Introduction of secondary adjustments into the UK’s transfer pricing legislation. The paper contains proposals for the introduction of further adjustments (secondary adjustments) to be permitted under UK transfer pricing rules to counteract the financial benefits of cash flows arising from non-arm’s length transfer pricing. It is arguable, however, that there are surely simpler ways of achieving the deterrent effect; for example, by increasing penalties in cases of more egregious non-arm’s length pricing.
.tmb-editorspic.jpg?sfvrsn=df04ab27_1)
