Fabrizio Lolliri, European director of transfer pricing at Hogan Lovells, and Catherine Clare, international tax manager at Tate & Lyle, a UK-based multinational agribusiness, explain how to make the most of your relationship with your transfer pricing adviser and how to review and set new transfer pricing policies, in the context of a large multinational enterprise.
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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