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International Experience in Transfer Pricing Regulations; Recent Developments in UK

International Experience in Transfer Pricing Regulations; Recent Developments in UK. Michael McCormack Director of Tax Edwards Wildman Palmer (UK) LLP June 2013. Recent Developments in UK Transfer Pricing. Background UK uncut Public Accounts Committee “devious, calculated…unethical”

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International Experience in Transfer Pricing Regulations; Recent Developments in UK

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  1. International Experience in Transfer Pricing Regulations; Recent Developments in UK Michael McCormack Director of Tax Edwards Wildman Palmer (UK) LLP June 2013

  2. Recent Developments in UK Transfer Pricing • Background • UK uncut • Public Accounts Committee • “devious, calculated…unethical” • Backlash

  3. Introduction to UK Transfer Pricing Rules • 1915 • 1998/2004 • Domestic/Firms • Thin capitalisation • Financing transactions • Advance pricing agreements • Advance thin pricing agreements • Balancing payments • Compensating adjustment • Dormant companies • Small and medium sized enterprises

  4. Operation of TP • Prescribed/Detailed • Arm’s Length • TP Document • Cost-plus • Safe-harbour • Profit Spilt

  5. Operation of TP System in the UK • Self-certify • Transfer pricing compliant • Enquiry • Transfer pricing group (TPG) • Clarity • Consistency • Business/Risk

  6. Business Risk Analysis • Industry • Pharmaceuticals • Online publishing/media • Telecoms • Service Centre/service cost recharges • Intellectual property • Documentation • Functional analysis • Accurate comparables • Research and development • Intra-group financing

  7. Tax Framework • UK most competitive tax system in G20 • Tax rate • Dividend exemption • Substantial shareholding exemption • Controlled foreign companies • Branch exemption

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