Expert Resources

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Paul Sutton

“A blatant revenue grab”

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 …
Paul Sutton

Should Intercompany Agreements be put in place between a ‘parent’ company and its own permanent establishment / branch?

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 …