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GROUPS


Have the OECD Guidelines changed the transfer pricing landscape? Is comparability analysis reliable? These questions amoungst others are debated by Erica Howard, Jonathan Levy, Shiv Mahalingham and HMRC's Richard Thomas in a Tax Journal round table

Kirsten White on whether advanced pricing agreements are the only way to resolve international issues

Paul Morton on tax competitiveness

Michael Bell and Clara Howard look at what lessons we can learn from demergers

Sarah Churton examines the issues that groups need to analyse when considering a relocation of their parent company

Where are we now? Michael Bird reviews the impact of latest developments

Pete Miller examines the two ways for the amalgamation of corporate activities

Nick Foster-Taylor looks at practical and commercial issues arising when multinationals carry out restructuring, and discusses the impact that transfer pricing has on business and operational considerations

Once a decision has been taken to see a business, the optimal sale structure should be determined. Hilary Barclay examines the key tax considerations

HMRC's draft guidance on debt-buy backs by connected companies is reviewed by Richard Carson

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