Transfer Pricing

​Commercial Objectives - Joel Cooper, DLA Piper (Transfer Pricing, London, 05.12.17) Is there any wriggle room as worldwide tax authorities adopt similar approaches to transfer pricing and sharing information, with reference to the EC’s stance on APAs and the OECD’s stance on BEPS?

• Date Uploaded: 5 Dec 2017
• Format: PDF
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BEPS MLI Arbitration and SDR - Peter Nias, Pump Court Tax Chambers (Transfer Pricing, London, 05.12.17) Despite all the noise, is arbitration actually the panacea for securing a final resolution to cross border tax disputes? Could SDR techniques more effectively complement the MAP process?

• Date Uploaded: 5 Dec 2017
• Format: PDF
• Size: 520.862 KB

Intangibles Valuations: Conversations with HMRC - Lyndsay MacGregor, Deloitte LLP (Transfer Pricing, London, 05.12.17) What is HMRC’s approach? What are the best methods for engaging with HMRC?

• Date Uploaded: 5 Dec 2017
• Format: PDF
• Size: 219.039 KB

Cash-Pooling - Douglas Keel, Radcliffe Chambers (Transfer Pricing, London, 05.12.17) Where is the line between cash pooling policies and inter-company debt, with reference to the rates you set and the potential for disguised long-term loans? How might secondary adjustments fit in?

• Date Uploaded: 5 Dec 2017
• Format: PDF
• Size: 235.65 KB

Litigating a Transfer Pricing Case - Francis Fitzpatrick QC, 11 New Square (Transfer Pricing, London, 05.12.17) What are the critical factors when litigating a transfer price case?

• Date Uploaded: 5 Dec 2017
• Format: PDF
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BEPS Actions 8-10 - Daniel Beeton, Duff and Phelps (Transfer Pricing, London, 05.12.17) How are you to apply (with any certainty) newly emerging valuation concepts and approaches when pricing hard-to-value intangibles, with reference to BEPS transfer pricing Actions 8-10?

• Date Uploaded: 5 Dec 2017
• Format: PDF
• Size: 500.223 KB

State Aid - Conor Quigley QC, Serle Court (Transfer Pricing, London, 05.12.17) What are the Apple and Fiat state aid decisions telling us about the EC unique version of the arm's length standard? Can any “sweetheart deal” with a multi-national stand up to state aid scrutiny?

• Date Uploaded: 5 Dec 2017
• Format: PDF
• Size: 316.863 KB