The Resource Annual review : United Kingdom

Annual review : United Kingdom

Annual review : United Kingdom
Annual review : United Kingdom
This article provides an overview of the transfer pricing developments of 2012 in the United Kingdom. It looks at (I) legislation (CFC, the Patent Box, transfer of assets abroad, general anti-abuse rule), (II) briefings, guidance and statements of practice (risk management, transfer pricing enquiries, intra-group funding, group loss relief following MAP, working a transfer price case, Advance Thin Capitalisation Agreements, managing large disputes, code of governance for resolving tax disputes, large business strategy), (III) other developments (the NAO report on the settling of large tax disputes by HMRC, transfer pricing statistics, International Development Committee report on tax in developing countries, joint transfer pricing audits, UK-UK transfer pricing) and (IV) future developments. Due to all developments, according to this article, MNEs can no longer have any certainty about their UK corporate income tax liabilities
Citation source
In: Transfer pricing international journal. - London. - Vol. 14 (2013),
  • Beeton, D
  • Clayson, M
Geographic coverage
  • Europe
  • European Union
Language note
  • transfer pricing
  • CFC
  • patent box
  • hive down
  • GAAR
  • risk management
  • group treatment
  • MAP
  • tax liability
Annual review : United Kingdom

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