When the Finance Bill 2015 receives Royal Assent in the next few weeks it will contain enabling legislation to usher in prescriptive documentation requirements for approximately 1,400 of the largest multi-national enterprises (“MNEs”) with a UK parent. The enabling legislation will give HM Treasury the power to make regulations via statutory instrument to implement the final recommendations for country-by-country … Continue reading Country-by-country, year by year – the compliance burden is increasing!
The Chancellor today announced three key measures to help the UK tackle Base Erosion and Profit Shifting (“BEPS”). The measures signal the first concrete BEPS related measures intended to be adopted into domestic legislation. The measures are part of the UK Government’s efforts to strengthen anti-avoidance measures and in the process promote fairness in tax … Continue reading BEPS takes centre stage as Chancellor ushers in special ‘Tech Tax’
On 16 September 2014, the Organisation for Economic Co-operation and Development (“OECD”) released a document titled “Guidance on Transfer Pricing Aspects of Intangibles” as a deliverable for Action 8 of the base erosion and profit shifting (“BEPS”) project. Within the document there are the final revisions to Chapters I, II and VI of the OECD … Continue reading BEPS Guidance on Transfer Pricing Aspects of Intangibles
The Chancellor today published a paper setting out the UK’s priorities for the G20-OECD project on Base Erosion and Profit Shifting (“BEPS”). The paper, titled “Tackling aggressive tax planning in the global economy: UK priorities for the G20-OECD project for countering Base Erosion and Profit Shifting” re-affirms the UK Government’s commitment to adopt any BEPS compliance measures … Continue reading Chancellor sets out the UK’s priorities for the G20-OECD BEPS project
HMRC already has one of the best organised and most efficient transfer pricing capabilities of any revenue authority in the world and is often asked to advise other revenue authorities on how they should approach transfer pricing. The additional investment in HMRC resources announced in the Autumn Statement today signals that HMRC is about to get even stronger. … Continue reading Buckle Up! Expect more Transfer Pricing enquiries and adjustments as HMRC gets set for additional resources with which to tackle Transfer Pricing
Wilting under the intense heat of public opinion, Starbucks announced its decision to open talks with HMRC with a view to restructuring its tax affairs so it becomes tax paying in the UK. Starbucks did this in direct response to the damage to its brand in the court of UK public opinion. This is understandable given that … Continue reading An ‘extra shot’ for Starbucks: why paying more tax in the UK is a great idea!
Recent adverse publicity for Starbucks, Amazon and Google has put transfer pricing at the centre of a very public debate on the responsibility of corporates to pay not only the right amount of tax, but also the fair amount of tax. This debate is set to continue as corporates find themselves under intense public scrutiny, … Continue reading Transfer Pricing in the dock: time for a well informed and reasonable public debate
The Budget did not signal any changes to the Transfer Pricing rules which is most welcome at this time as there is a packed schedule of initiatives over the next 12 months for transfer pricing at the OECD level, chief of which is the review and likely re-write of Chapter VI (Special Considerations for Intangible Property) and Chapter VIII … Continue reading Increasing reliance on Transfer Pricing principles?