Outside expertise will allow the UK tax authorities to attack transactions they view as risky with a whole new level of sophistication, says Ted Keen of the Ballentine Barbera Group, a CRA International company. UK taxpayers who have not yet done so should revisit their transfer pricing documentation, particularly where transfers of valuable intangible property are concerned
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Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires
Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences
Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default
Despite legislative gridlock, international investors should be wary of legal precedents set by recent court rulings, which could substantially alter the Spanish tax environment