Expert Resources

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Paul Sutton

Schrödinger’s cat and intercompany agreements

Paul Sutton Intercompany Agreements
Erwin Schrödinger was Nobel Prize-winning Austrian physicist. You’ve probably heard of him. He created a thought experiment in 1935 to point out the contradiction between what quantum theorists held to be true at the atomic and subatomic level, and what the average person observes to be true on the macroscopic level. The experiment went something …
Paul Sutton

HMRC’s Profit Diversion Compliance Facility – Private Discussion Group with Mark Carnduff

Paul Sutton Events & Seminars, Intercompany Agreements
Following HMRC’s announcement of the Profit Diversion Compliance Facility (PDCF), a number of multinational groups have received so-called ‘nudge’ letters from HMRC, encouraging them to consider registering for the facility. Still more groups have made unprompted disclosure, or are in the process of preparing to make disclosure. On 27 June 2019, …
Paul Sutton

China APA stats

Paul Sutton Intercompany Agreements
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 …
Paul Sutton

HMRC Announces New Profit Diversion Compliance Facility

Paul Sutton Intercompany Agreements
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 …
Paul Sutton

Error in TP Master File – what would you do?

Paul Sutton Intercompany Agreements
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 …