Since the arm's-length principle was introduced in Peru in 2001, there have been multiple updates and extensions to the rules on transfer pricing. Claudia González-Béndiksen and Paola Gutiérrez list the important points taxpayers must be aware of, such as maintaining stringent documentation as well as filing an annual sworn informative return.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap