HMRC identifies and discusses some of the main points it sees coming out of the ground-breaking transfer pricing litigation in DSG Retail before the Special Commissioners
The Special Commissioners' decision in DSG Retail Ltd and others v HMRC TC00001 is the first on the UK's current transfer pricing legislation including its application in accordance with the OECD Transfer Pricing Guidelines. It gives much clear and valuable guidance on transfer pricing methodology as well as on the law. This short article concentrates on highlighting some of the key points from the decision. The facts concerning DSG's arrangements in relation to the sale of extended warranties (EWs) on domestic electrical goods (DEGs) insured within the Group are set out in the decision at www.lexisurl.com/t4u7H.
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HMRC identifies and discusses some of the main points it sees coming out of the ground-breaking transfer pricing litigation in DSG Retail before the Special Commissioners
The Special Commissioners' decision in DSG Retail Ltd and others v HMRC TC00001 is the first on the UK's current transfer pricing legislation including its application in accordance with the OECD Transfer Pricing Guidelines. It gives much clear and valuable guidance on transfer pricing methodology as well as on the law. This short article concentrates on highlighting some of the key points from the decision. The facts concerning DSG's arrangements in relation to the sale of extended warranties (EWs) on domestic electrical goods (DEGs) insured within the Group are set out in the decision at www.lexisurl.com/t4u7H.
...
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