EY Global Tax Controversy Flash Newsletter (Issue 53) | UK transfer pricing adjustments – is the underlying rule being followed?

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EY Global

13 Dec 2022 PDF
Subject Tax Alert
Categories Corporate Tax
Jurisdictions Global

As transfer pricing controversy increases, taxpayers should consider looking to the legislation underpinning tax administrations’ challenges.

In a recent articlePaula Ruffell, Senior Manager, Ernst & Young LLP, and Joel Cooper, EY Global International Tax and Transaction Services Controversy Leader, explore Section 147 of the Taxation (International and Other Provisions) Act (TIOPA) 2010, the UK transfer pricing rule. They review when and how the UK tax authority, HM Revenue & Customs (HMRC), can make transfer pricing adjustments. Specifically, the authors examine whether the basic precondition point of Section 147 (that the taxpayer’s self-assessment differs from an arm’s length provision) is consistently being satisfied before HMRC makes a transfer pricing determination.

Additional information and links to past newsletters can be found in the attached PDF.

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