Just in case you’re interested in these things: last month, China’s State Administration of Taxation (“SAT”) published its annual report on Advance Pricing Arrangements (APAs). The report covers the period from 2005 to 2017. According to the report, China’s APA programme still deals primarily deals with inbound MNE applicants. Here are the …

‘The God of small things’ or ‘the Devil in the detail’ – you choose, depending on how you’re feeling this fine morning. Either way, one theme highlighted by HMRC’s announcement on 11th January is the critical importance of robust implementation of Transfer Pricing compliance strategies. In relation to legal implementation, as with …

On 10 January 2019 HMRC announced a new Profit Diversion Compliance Facility (PDCF) to encourage multinational enterprises (MNEs) to make voluntary disclosures about mistakes or failures to notify in respect of profits diverted from the UK. Full details of the announcement can be found here. Why have HMRC announced a new Profit Diversion Compliance …

This kind of situation seems to be coming to light more and more frequently – perhaps as the reality of transfer pricing compliance kicks in. I would be very interested to hear what you would do about it. A typical scenario is as follows: A multinational group’s business activities include the sale of products, and the supply chain is described …

One of the interesting things about intra-group licensing of intellectual property and intangibles, is how it’s often inextricably linked with related transactions such as the sale of goods. This can create customs duties risks, which need to be managed alongside transfer pricing compliance and the group’s intellectual property protection …

How long is arm’s-length? This issue came up at a seminar on intercompany agreements hosted by Thomson Reuters Onesource at their Canary Wharf headquarters last Friday, at which I was guest speaker (thank you Sally, Amy, Dickson and Chris!). It’s a point we feel very passionate about and obviously we’re not doing enough to get the message out. …