Transfer pricing

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VAT treatment of damages and compensation paymentsFORTHCOMING CHANGE: HMRC is in the process of revising Revenue and Customs Brief 12 (2020) on the...
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19th May
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Amortisation of intangible fixed assetsWhere a company acquires (or otherwise incurs capitalised expenditure upon) an intangible fixed asset that...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
EIS—deferred gain becomes chargeable to CGTCoronavirus (COVID-19): In response to the coronavirus (COVID-19) pandemic, the government introduced a...
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19th May
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Property holding structures—SDLT and VAT treatment of a Jersey Property Unit Trust (JPUT)IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the...
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19th May
Practice notes
Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)STOP PRESS relating to property rich collective investment...
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19th May
Practice notes
Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
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Produced in partnership with Martin Scammell 19th May
Practice notes
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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19th May
Practice notes
FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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19th May
Practice notes
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 19th May
Practice notes
Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
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19th May
Practice notes
Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
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Produced in partnership with Zoe Feller of Bird & Bird 19th May
Q&As
Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
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19th May
Practice notes
Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
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19th May
Practice notes
SDLT group reliefFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports, the government announced...
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19th May

Most recent Transfer pricing content

Practice notes
What is transfer pricing?Transfer pricing is a concept that refers to the pricing of goods, services, funds and tangible and intangible assets...
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Produced in partnership with Simon Gough and Caroline Brown of Bird & Bird LLP 21st Jul
Practice notes
Transfer pricing of loans and guaranteesApplication of UK’s transfer pricing rules to loansUK legislation includes transfer pricing rules, which...
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Produced in partnership with Andréa Leho of Macfarlanes 15th Jul
Practice notes
Characterisation of entities for transfer pricing purposesFunctional analysisA key component of the arm's length principle is the requirement to...
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Produced in partnership with Robert Langston of Saffery Champness 30th Jun
Practice notes
Transfer pricing and private equity transactionsIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Batanayi Katongera of Macintyre Hudson 30th Jun
Practice notes
Establishing an arm's length price for transfer pricing purposesArm's length principleThe arm’s length principle is endorsed by the OECD (Organisation...
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Produced in partnership with Joel Cooper, Rachit Agarwal and James Dalley of DLA Piper 24th Jun
Practice notes
When is the UK participation condition met?IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation...
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Produced in partnership with Robert Langston of Saffery Champness 24th Jun
Practice notes
What happens when the transfer pricing rules apply?IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Joel Cooper, Rachit Agarwal and James Dalley of DLA Piper 24th Jun
Q&As
Does a connected entity as defined in section 1122 of the Corporation Tax Act 2010 (CTA 2010) or an associated company with the meaning of section 449...
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23rd Jun
Q&As
Which types of persons are within the UK transfer pricing regime?The UK’s transfer pricing regime applies to ‘persons’ and therefore includes...
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23rd Jun
Practice notes
When do the UK transfer pricing rules apply?IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation...
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Produced in partnership with Simon Gough and Caroline Brown of Bird & Bird LLP 23rd Jun
Q&As
Does the UK (or HMRC in practice) express a preference for a particular transfer pricing method for establishing an arm’s length price of interest,...
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5th Jun
Q&As
What method will HMRC use when determining an arm's length interest rate on a related party loan?In this Q&A we have assumed that the lending in...
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5th Jun
Practice notes
Transfer pricing and joint venturesThis Practice Note considers the UK tax aspects of the application of the UK’s transfer pricing rules to joint...
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Produced in partnership with Simon Gough and Caroline Brown of Bird & Bird LLP 5th Jun

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