Corporation Tax

Transfer pricing ― setting up overseas

Produced by Tolley
  • 08 Feb 2022 09:27

The following Corporation Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:

  • Transfer pricing ― setting up overseas
  • General principles
  • Funding the overseas business

Transfer pricing ― setting up overseas

General principles

Transfer pricing tax rules exist to counter the opportunity for groups to reduce their global tax burden by shifting profits to low tax jurisdictions through group pricing, eg by selling goods at cost from a company in a higher tax jurisdiction to one in a lower tax jurisdiction. Without tax rules to counter this, the company in the lower tax jurisdiction would make higher profits through its lower cost of sales. The company in the higher tax jurisdiction would have minimal taxable profits that do not necessarily reflect the commercial risk and business

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