UK Transfer Pricing 2012-13

Taxation › U.K. › Transfer Pricing

UK Transfer Pricing 2012-13

Edited by David Abrehart · Paul Daly · Nick Drizen · Nick Foster-Taylor
LexisNexis U.K. October 2012

Specifications

ISBN-13
9780754547556
Publisher
LexisNexis U.K.
Publication
October 2012
Format
Paperback
Jurisdiction
U.K. ? Countri(es) for reference only

Details

The last year has seen significant amendments to UK transfer pricing guidance, with more changes anticipated.  There have also been legislative and case law developments which have brought into question the compliance of the UK’s transfer pricing rules with European Union (EU) law.  The interaction of transfer pricing with other areas of tax law can be complex with several special sets of transfer pricing rules for specific issues in different parts of the Taxes Acts.  It is crucial that practitioners working in this area understand and are up–to–speed with any changes in transfer pricing so that they are able to effectively advise clients.  UK Transfer Pricing 2012–13 explores all of the above issues in a style that is both comprehensive and informative, through the use of numerous practical examples and case studies. 

  • Expert author team from top firms in the Transfer Pricing field, including BDO; Grant Thornton; CMS Cameron McKenna; EY; PKF and Alvarez & Marsal.
  • Multi–contributed so covers many different perspectives and explores many areas of transfer pricing;
  • Includes practical case studies and examples from top firms such as McGrigors and KPMG.

Table of Contents

  • Fundamental Sources;
  • Selected Leading Cases;
  • The Arm's Length Principle and Comparability;
  • Associated Enterprises;
  • Recharacterisation Issues;
  • Functional Analysis;
  • Analysis of Functions, Assets and Risk;
  • Relating Functional Analysis to Selection of TP Method;
  • Transfer Pricing Methods;
  • Choice of TP Method;
  • Comparability Analysis - OECD Proposed Process;
  • Comparability Analysis Aggregation and Use of Non Third Party Transactions;
  • Comparability Analysis - Sources of Information & Timing Issues;
  • Comparability Adjustments;
  • The Arm's Length Range;
  • Comparability Compliance Issues;
  • Specific Transactions:
  • Intra-Group Services;
  • Specific Transactions:
  • Finance;
  • Specific Transactions: IP;
  • Specific Transactions: Business Restructuring;
  • Permanent Establishments;
  • Compliance Issues;
  • Avoiding Double Taxation & Dispute Resolution;
  • MAP

About the Author

This is a multi-contributed title and firms involved include: BDO LLP; CMS Cameron McKenna; Alvarez & Marsal; Moore Stephens; PKF; Grant Thornton; and Ernst & Young

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