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Why transfer pricing is becoming more demanding

Speed Read: With the adoption of its Litigation and Settlement Strategy HMRC is expected to pursue the transfer pricing enquiries it opens rigorously. More will be demanded of analyses in such cases as is illustrated in the proposed revisions to the OECD's Transfer Pricing Guidelines and evidenced in the detailed economics-based scrutiny of transfer pricing arrangements and comparables in the Dixons ruling and other cases around the world. Where risk-assessment highlights a potential exposure to challenge an approach will be warranted that goes beyond basic documentation and penalty protection. This will increase costs for some — but not all — taxpayers but also form the starting point for more strategic value-adding and and robust solutions.
More than a decade has passed since the introduction of new transfer...

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