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Vol 24 No 9 Sept/Oct 2019

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The Anti-Suit Injunction

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Global Transfer Pricing: Principles and Practice 4th ed

ISBN13: 9781526511218
Previous Edition ISBN: 9781780439822
Published: August 2019
Publisher: Bloomsbury Professional
Country of Publication: UK
Format: Paperback
Price: £120.00

Despatched in 8 to 10 days.

The previous edition was published shortly after the end of the OECD BEPS recommendation phase had finished and we are now well into the implementation phase, with much follow-up work having been done on the original Actions. Therefore this new edition will include:-

  • an update on implementation of BEPS recommendations, including artificial avoidance of permanent establishment status and prevention of treaty abuse
  • implementation of transfer pricing documentation and country-by-country reporting
  • multilateral instrument implementation. In particular:
  • Chapter 5 'Types of Transaction: Financing' will be updated to include commentary on the OECD discussion draft on transfer pricing aspects of financial transactions, including treasury function, guarantee fees and captive insurance
  • Chapter 7 will be expanded to cover new guidance on profit split and the recent trend towards profit split in HMRC enquiries
  • The 'UK' chapter will include new content on interest restriction rules and transfer pricing, penalties for non-compliance, rules governing the conduct of transfer pricing audits and also Brexit considerations
  • A new chapter will be added on the 'Allocation of profits to branches' to cover Articles 7 and 9 and work with Financial Services teams on Financial Services branches.
Legislation and case law:
  • OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2017)
  • Individual OECD BEPS Reports detailing revised guidance on the BEPS Action Plan, including the OECD/G20 Inclusive Framework on BEPS: Progress Report (July 2018)

1: Transfer Pricing: What is it?
3: Types of transaction: Tangible goods
4: Types of transaction: Intra-group services
5: Types of transaction: Financing
6: Types of transaction: Intangibles
7: Profit split
8: Business restructurings
9: Transfer pricing documentation
10: Operational transfer pricing
11: Tax audits and eliminating double taxation
12: UK transfer pricing legislation
13: Allocation of profits to branches
Appendix A: United Kingdom Transfer Pricing Summary
Appendix B: International Quick Reference Guide 2016