Transfer Pricing Rules

BEPS amendments to Chapter 1 of the OECD TP Guidelines

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The 2013 Organisation for Economic Co-operation and Development (OECD) Action Plan on Base Erosion and Profit Shifting (BEPS) recognised that existing internationally agreed rules for transfer pricing could be misapplied, resulting in outcomes where the allocation of profits is not aligned with the economic activity that produced those profits.

Of the fifteen Action Points in the BEPS Project, Actions 8 – 10 directly addressed transfer pricing and the arm’s length principle. Read the rest of this entry »


What is the “provision” in UK transfer pricing?

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Transfer pricing is an important cross-border tax issue. The UK transfer pricing rules are contained in Part 4 of the Taxation (International and Other Provisions) Act 2010, normally referred to as TIOPA10.

This note considers the meaning of “provision” in UK transfer pricing, including the situation where the actual provision relates to debt, and asks you to consider what the allowable interest deduction should be in a simple (?) example. Read the rest of this entry »