Diane Hay, former deputy director, CT & VAT and head of the Transfer Pricing Group at HM Revenue & Customs in the UK tells Catherine Snowdon about some of the main difficulties she tackled while at the revenue authority, offers taxpayers an insight into how transfer pricing cases are selected and talks about the future of transfer pricing.
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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
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