The debate on the future of the arm’s-length standard (ALS), at International Tax Review's Global Transfer Pricing Forum in Amsterdam today, concluded that, while interesting arguments exist for an alternative method, the ALS is the only viable option because of its close connection to what happens in the market.
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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