The accepted standard for transfer pricing has always been the transfer pricing guidelines issued by the OECD. However, that may be changing as China and other developing countries set out their stall in the new UN practical manual on transfer pricing. Glenn DeSouza of Baker & McKenzie in Shanghai analyses what this will mean for multinational businesses.
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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