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Transfer pricing
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Transfer pricing
TRANSFER PRICING
Are ‘provisions’ synonymous with ‘conditions’ in UK transfer pricing? A debate following BlackRock
Sarah Bond
Batanayi Katongera
Batanayi Katongera (in-house specialist) and Sarah Bond (Freshfields
Bruckhaus Deringer) discuss whether the UK terms should be given the
broader meaning of the OECD concepts in order to bring greater clarity
and reduce the risk of double taxation.
BlackRock: no imputation of covenants for transfer pricing purposes
Paul Sutton
The Upper Tribunal’s decision on the transfer pricing aspects of the
BlackRock
case is an overly restrictive interpretation of the law, writes Paul Sutton (LCN Legal).
Transfer pricing: new guidance on hard to value intangibles
Anton Hume
Vladimir Milic
The guidance on HTVIs is likely to have a considerable impact on the development of transfer pricing compliance, write Vladimir Milic and Anton Hume (BDO).
Transfer pricing: documentation proposals and disputes
Sarah Bond
Sarah Bond (Freshfields Bruckhaus Deringer) considers the implications for businesses of the proposed changes to required transfer pricing documentation currently under consultation.
Covid-19 and transfer pricing
Five key lessons from the OECD’s new guidance.
Transfer pricing guide to cash pooling arrangements
John W. Lamszus
Daniel J. Pugh
Selena Schneider
Selena Schneider, John W. Lamszus and Daniel J. Pugh (Crowe) provide a guide to this common treasury management tool used by multinationals to efficiently manage cash and reduce process and transaction costs.
Transfer pricing for financial transactions: what just changed?
Fan Bai
Monique van Herksen
Clive Jie-A-Joen
The OECD's new guidance marks a change in approach, as experts at Simmons & Simmons explain.
The transfer pricing of financing transactions: OECD guidance
Andrew Stewart
Anton Hume
We are expecting new OECD guidance on the transfer pricing analysis of financing arrangements. Anton Hume and Andrew Stewart (BDO) consider what’s most likely to change.
How to handle HMRC transfer pricing enquiries
Paul Daly
Ben Henton
Transfer pricing enquiries are becoming a commonplace challenge within the UK tax landscape. Paul Daly and Ben Henton (BDO) examine the practical issues.
FA 2019: hybrid mismatch rule
Richard Cherrett
In 2017, the UK implemented a detailed set of hybrid mismatch rules to combat cross-border tax advantages arising from hybridity for example, the differing tax treatments of entities, transactions or instruments. The...
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EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
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HMRC v Boehringer Ingelheim Ltd
R (oao Rokos) v HMRC
Other cases that caught our eye: 10 April 2026
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Provisions
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J Hosking v HMRC
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Case watch
Staggered roll-out for mandatory tax adviser registration
Consultation tracker