UK controlled foreign company (CFC) rules are going through a period of change. The government is trying to develop EC compliant legislation that achieves the twin objectives of minimising tax leakage through avoidance, while not being perceived as a barrier to business, so allowing the UK to remain commercially competitive, explains Ross Welland, tax partner at Haines Watts.
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Arindam Mitra and Robin Hart examine how aggregate TP rules clash with transaction-level customs rules, creating compliance risks and requiring granular, SKU-level pricing strategies
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