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.
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The OECD had previously missed a June 30 deadline to agree an MLC on amount A; in other news, UK corporation tax bills surged to a record high last year