Expert Resources

Take advantage of our free expert resources, written by the experts at LCN Legal, based on their practical experience of working with multinational groups and their advisers across the globe. If you are interested in these areas, you may wish to bookmark this page to check back regularly for new information.

Paul Sutton

HMRC Announces New Profit Diversion Compliance Facility

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?

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 …
Paul Sutton

How long is arm’s-length?

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. …
Paul Sutton

China Customs duties on royalties – unexpected risks for multinational groups operating in China

We are delighted to feature this article, which has been kindly contributed by Harvey Lee, Senior Partner at Shanghai Kingfaith Consulting Co. Harvey’s contact details can be found at the end of the article. The payment of royalty and license fees by a Chinese subsidiary to its foreign parent company is a common feature of transfer pricing (TP) arrangement …