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Vol 21 No 9 Sept/Oct 2016

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Goode on Commercial Law

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UK Transfer Pricing 2012-13

ISBN13: 9780754547556
Published: October 2012
Publisher: LexisNexis Butterworths
Country of Publication: UK
Format: Paperback
Price: £154.30

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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.

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:
Specific Transactions: IP
Specific Transactions: Business Restructuring
Permanent Establishments
Compliance Issues
Avoiding Double Taxation & Dispute Resolution