Once an obscure science practiced by the Big Four, transfer pricing has become part of the mainstream tax job market as companies seek out TP expertise. Transfer pricing professionals are now asking what kind of skills they need to become a strategic partner in their business.
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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