Functional analysis A key component of the arm's length principle is the requirement to conduct a functional analysis to determine whether controlled and uncontrolled...
Arm's length principle The arm’s length principle is endorsed by the OECD (Organisation for Economic Co-operation and Development) and enshrined in the Associated...
This Practice Note considers the UK tax aspects of the application of the UK’s transfer pricing rules to joint ventures, including in particular, when the rules apply and...
This Practice Note discusses the transfer pricing considerations that typically arise on a UK-based private equity buyout deal. What is a private equity buyout? The...
Application of UK’s transfer pricing rules to loans The UK has specific rules in its legislation which should be read together with HMRC published guidance on intra-group...
Calculation of profits and losses Where the transfer pricing rules apply (for which, see Practice Note: When do the UK transfer pricing rules apply?), the profits and...
Transfer pricing is a concept that refers to the pricing of goods, services, funds and tangible and intangible assets transferred or provided between associated parties....
Scope of UK transfer pricing rules The UK transfer pricing rules apply where: • a provision has been made or imposed between two persons by means of a transaction or...
Participation condition The UK transfer pricing rules only apply to provisions between two persons where the participation condition is satisfied. The participation...