The treatment of implicit and explicit guarantees is one of the issues raised in the OECD’s discussion draft paper on financial transactions, which was released for comment in July this year. The discussion in section D of that paper mainly relates to loans made by an independent third party to a group company, and the pricing of guarantee fees which …

I’m hugely excited to be a guest speaker at a seminar hosted by Thomson Reuters at its London headquarters in Canary Wharf on Friday 30 November. The event will be from 09:30–12:00 noon GMT, and the subject of the seminar will be “Intercompany Agreements – Bringing together Tax & Legal.” We’ll look to address some of the following …

This was the reaction from Kevin Brady, Chairman of the US House of Representatives Ways and Means Committee, to the announcement in last week’s budget in the UK regarding the proposed introduction of a ‘Digital Services Tax’: “The United Kingdom’s introduction of a new tax targeting cross-border digital services – which mirrors a similar …

This question came up again last week on a transfer pricing project (many thanks to AH and NA for raising it!). The issue was how the relationship between ‘parent’ company and its own branch / permanent establishment (PE) should be documented – and specifically the use of a memorandum vs a document in the style of an agreement. The first and most …