Expert Resources

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Legal Resources

Briefing on how to create effective Intercompany Agreements for Transfer Pricing

Intercompany Agreements

Issue of Quoted Eurobonds to Related Parties – Preliminary Legal Information Request

Group Reorganisations

Special Report for Legal Counsel – OECD’s Transfer Pricing Guidelines (2017)

Intercompany Agreements

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Xiaofang Sutton

What Jim Rohn would say to a Mum Entrepreneur?

Xiaofang Sutton Personal Blog
My husband and I have this habit of asking the question of what a famous successful public figure would say or do if he/she was in our situation. Last week, I was having one of those days where I was trying to finish work on time and get to the bottom of that never ending to do list, but I didn’t. Everything after that was just a blur for me; I rushed …
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 …