In transactions between related entities across jurisdictions, transfer pricing rules act to allocate profits and losses in a fair and economically justifiable manner to best reflect revenues and costs of each party to the transaction. Bruce Clements and Alan Clements of Clements Law Office discuss the factors in applying the comparability approach in the US and the UK.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
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