Implications that HMRC guidance has for transfer pricing policies
Transfer pricing does not get much more complex than the OECD鈥檚 control of risk framework鈥攚hich different tax authorities interpret in different ways. But the punchline of new guidance from the HMRC clarifying their interpretation of the framework is simple: when businesses have senior personnel in the UK and those personnel are responsible for making decisions about key business risks, they need to think about what implications that HMRC guidance has for their transfer pricing policies.
Read a聽*聽[PDF 213 KB] prepared by 乐鱼(Leyu)体育官网 professionals:聽HMRC Guidance: A New Transfer Pricing Risk to Control
* Reproduced with permission from Tax Management International Journal, 1/30/2024. Copyright @ 2024 by Bloomberg Industry Group, Inc. (800-372-1033) http://www.bloombergindustry.com