Alison Lobb and Clive Teitjen look at the recent trend for incorporating the arm's-length principle into areas of the UK corporate tax code beyond the transfer pricing rules
A recent trend is for new UK corporate tax legislation such as the patent box and new controlled foreign companies (CFC) rules to include requirements for businesses to calculate profits for specific tax purposes on an arm’s-length basis using the same principle as the one that underpins existing transfer pricing rules. There are several factors influencing this trend:
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