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© 2013 Edwards Wildman Palmer LLP & Edwards Wildman Palmer UK LLP 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” ♦ Backlash 2
Introduction to UK Transfer PricingRules ♦ 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 3
Operation of TP ♦ Prescribed/Detailed ♦ Arm’s Length ♦ TP Document ♦ Cost-plus ♦ Safe-harbour ♦ Profit Spilt 4
Operation of TP System in the UK ♦ Self-certify ♦ Transfer pricing compliant ♦ Enquiry ♦ Transfer pricing group (TPG) ♦ Clarity ♦ Consistency ♦ Business/Risk 5
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 6
Tax Framework ♦ UK most competitive tax system in G20 ♦ Tax rate ♦ Dividend exemption ♦ Substantial shareholding exemption ♦ Controlled foreign companies ♦ Branch exemption 7
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