TRANSFER-PRICING

Mark Bevington (ADE Tax) highlights the areas where the new TP and UTPP rules do not appear to work as intended.

In this month’s review, Sophie Dworetzsky (Charles Russell Speechlys) examines a case on distributions from an offshore company, a potentially farreaching proposed change to the definition of permanent establishment and the latest HMRC guidance.

Closure notices, DPT and transfer pricing

Phil Maggs

Phil Sneade

Phil Maggs and Phil Sneade (Frontier Economics) explain why it is usually wrong to argue for a ‘risk-free’ return for capital at arm’s length.

Robert Langston

Robert Langston (Saffery) explains why it is necessary to consider international tax principles, such as entity classification and transfer pricing, alongside the disguised investment management fee rules.

Helen Buchanan

Sarah Bond

The Court of Appeal judgment restores order, write Sarah Bond and Helen Buchanan (Freshfields Bruckhaus Deringer).

Robert Langston

Robert Langston (Saffery) provides a practical case study on the operation of the corporate interest restriction where related party guarantees and withholding tax issues are involved.

Court of Appeal overturns Upper Tribunal decision on transfer pricing but upholds conclusion on unallowable purpose.

Charles Havisham

Phil Roper

The thrust of HMRC’s guidance is to reject the notion that a profit split shouldn’t be used to reward risk control contributions, write Phil Roper and Charles Havisham (KPMG).

Zoe Andrews

Mike Lane

The Court of Appeal’s decision in Dolphin Drilling and consultation responses on the modernisation of transfer pricing, DPT and PEs are among the recent developments in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).

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