TRANSFER PRICING

Sarah Bond

Sarah Bond and Benjamin Crompton (Freshfields) examine the draft legislation that amends certain aspects of the rules on transfer pricing and the diverted profits tax.

Uwe Zoellner Monia Volpato Rachit Agarwal

Rachit Agarwal, Monia Volpato and Uwe Zoellner (DLA Piper) set out the transfer pricing aspects that should be considered during the acquisition process.

Gary Barnett

Jo Crookshank

VAT developments concerning transfer pricing adjustments, tripartite arrangements and the Tour Operators Margin Scheme are examined in this month’s review by Jo Crookshank and Gary Barnett (Simmons & Simmons).

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.

Simon Wood

HMRC are clearly not happy with the standard of analysis and documentation that they are currently seeing, writes Simon Wood (BDO).

Paula Ruffell

Astrid Vroom

Paula Ruffell and Astrid Vroom (EY) consider the implications of Refinitiv to transfer pricing methodologies adopted in multiple years and what this means for APAs and DPT assessments more generally.

Joel Cooper

Paula Ruffell

Joel Cooper and Paula Ruffell (EY) outline the steps to consider if a ‘protective’ discovery assessment is issued for a transfer pricing matter.

David Murphy

David Murphy (BSI Group) explains why, for transfer pricing purposes, the cost influence curve could be a rational starting point for contribution analysis when allocating residual profits.

Peter Adriaansen

Pierre-Antoine Klethi

This judgment deals a blow to the European Commission’s state aid investigations concerning tax rulings on transfer pricing, writes Pierre-Antoine Klethi and Peter Adriaansen (Loyens & Loeff).

Philip de Homont

Paul Sutton

Paul Sutton (LCN Legal) and Philip de Homont (Nera Economic Consulting) set out a framework when considering the allocation of risks in transfer pricing.

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