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TRANSFER PRICING


‘There's absolutely no question of HMRC softening its approach to tackling avoidance, and HMRC will continue to ensure that everyone pays the right tax,’ a spokesman told Tax Journal after reports suggested that tax officials were to take a softer stance on avoidance.

The OECD announced the approval of the 2010 versions of its model tax convention, transfer pricing guidelines and report on the attribution of profits to permanent establishments.

Your impartial need-to-know guide to the coalition Government's emergency Budget

Chris Morgan rounds up the latest developments in the international tax world

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

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

Matthew Moriarty reviews whether guarantee fees pose a looming transfer pricing risk

Review of budget proposals by Chris Morgan and Alastair Munro

Peter Cussons on international taxation

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