Features and articles
Tax news in brief 25 September 2024
- Article
- 25 Sep 2024
Highlights from the broader tax news for the week ending 25 September 2024, including: new guidance from HMRC on transfer pricing and VAT compliance; updated HMRC bank details for some taxes and duties; and a reminder from HMRC to register for self assessment by 5 October 2024.
UK international tax reform on the horizon?
- Article
- 23 Jan 2024
There is broad support for measures to reform the transfer pricing, permanent establishment and diverted profits tax rules.
DPT, transfer pricing and permanent establishment reforms: ICAEW responds
- Article
- 22 Aug 2023
ICAEW’s Tax Faculty welcomed HMRC proposals to make the UK legislation more closely aligned with OECD principles, but noted that there were good reasons to not fully adopt the OECD’s 2017 changes to the permanent establishment definition.
Tax news in brief 26 July 2023
- Article
- 25 Jul 2023
Highlights from the broader tax news for the week ending 26 July 2023, including: corporation tax filing for companies in insolvency; relief for foreign taxes in PAYE codes; HMRC guidance on negative earnings; and transfer pricing records regulations.
UK international tax legislation to be reformed
- Article
- 29 Jun 2023
The UK government is seeking views on reforming the UK rules on transfer pricing, permanent establishments, and diverted profits tax.
Draft Finance Bill 2022-23: enactment of OECD rules into UK law
- Article
- 22 Jul 2022
The draft legislation, announced on 20 July, includes the introduction of a top-up tax applicable to multinational business alongside changes to the UK transfer pricing documentation requirements.
The impact of work-from-anywhere policies
- Article
- 29 Jul 2021
What effect does a globally mobile workforce have on transfer pricing arrangements?
Transfer pricing documentation requirements to be made more robust
- Article
- 24 Mar 2021
Tougher requirements for transfer pricing documentation will better focus compliance interventions and bring more alignment with international approaches, according to HMRC. ICAEW’s Tax Faculty outlines a new consultation on updating rules.
Bloomsbury Accounting and Tax Service
Eligible firms have free access to Bloomsbury Professional's comprehensive online library, comprising around 80 titles from some of the country's leading tax and accounting subject matter experts. Find out who is eligible and how you can access the Accounting and Tax Service.
Exclusive
Transfer pricing
- eBook chapter
- 2024
- Satwaki Chanda, Steve Collings, Jacquelyn Kimber, Maria Kitt, David O'Keefe, Andrew Parkes
- Corporation Tax
A full chapter providing practical guidance on transfer pricing, including the OECD BEPS project and the UK transfer pricing rules.
Exclusive
Business restructuring
- eBook chapter
- 2023
- Roy Donegan
A chapter on business restructuring, including Chapter IX of the OECD Transfer Pricing Guidelines.
Exclusive
Global transfer pricing: principles and practice (fifth edition)
- eBook
- 2023
- Roy Donegan
Accessible introduction to transfer pricing – a complex and increasingly important area of business taxation.
Exclusive
Transfer pricing practice
- eBook chapter
- 2023
- Lynne Oats
- Principles of International Taxation
A chapter on transfer pricing, providing an introduction to its key principles, OECD guidelines, transfer pricing methods and the Arm's Length Principle.
Exclusive
Transfer pricing administration
- eBook chapter
- 2023
- Lynne Oats
- Principles of International Taxation
A chapter on transfer pricing administration, covering the documentation requirements before looking at dispute resolution, the penalties that can apply in transfer pricing cases and finally, the use of advanced pricing arrangements and other forms of cooperation.
Terms of use
You are permitted to access, download, copy, or print out content from eBooks for your own research or study only, subject to the Acceptable usage terms.
The Library & Information Service provides a collection of eBooks as a benefit of membership. Please log in to access these titles. If you are unable to access an eBook, please see our Help and support or contact library@icaew.com.
Exclusive
Anti-avoidance
- eBook chapter
- 2023
- IBFD
- IBFD
A section providing an overview of the UK's anti-avoidance rules relating to corporate taxation. Covers the general anti-abuse rule (GAAR), disclosure of tax avoidance schemes (DOTAS) rules, Pillar Two, transfer pricing legislation, limitations on interest deductibility, the controlled foreign company (CFC) charge, and the legislation on hybrid mismatches.
Exclusive
Transfer pricing in relation to businesses in economic and financial distress
- eBook chapter
- 2023
- Raffaele Petruzzi, Abhishek Padwalkar
- IBFD Publications USA
A chapter examining the challenges which may arise in the performance of transfer pricing analysis and the application of transfer pricing rules in times of economic instability. The authors make some suggestions as to how such challenges might be successfully navigated.
Exclusive
Introduction to transfer pricing
- eBook
- 2022
- Jerome Monsenego
- Wolters Kluwer
Illustrates the fundamentals of transfer pricing with examples based on the business models used by multinational enterprises. Includes relevant court cases from various countries.
Exclusive
Compliance issues and transfer pricing disputes
- eBook chapter
- 2022
- Jerome Monsenego
- Wolters Kluwer
- Introduction to Transfer Pricing
A chapter examining two administrative concerns linked to transfer pricing: the need to enforce certain compliance rules, and the prevention and resolution of cross-border transfer pricing disputes.
Exclusive
Anti-avoidance
- eBook chapter
- 2021
- Malcolm James
- Spiramus
A chapter summarising HMRC's present strategy with regard to tax avoidance. Includes an overview of the various rules and legislation in this area.
Exclusive
Fundamentals of transfer pricing: general topics and specific transactions
- eBook
- 2021
- Michael Lang, Giammarco Cotani, Raffaele Petruzzi
- Wolters Kluwer Law International
This guide explores the practical application of transfer pricing rules, offering examples and international judicial precedents. Chapters cover transfer pricing methods, approaches to prevent and resolve disputes, documentation, attribution of profits to permanent establishments, and specific transactions (such as services, financing, intangibles and business restructurings).
Terms of use
You are permitted to access, download, copy, or print out content from eBooks for your own research or study only, subject to the terms of use set by our suppliers and any restrictions imposed by individual publishers. Please see individual supplier pages for full terms of use.
Industry press
The ICAEW Library & Information Service provides access to a range of leading tax journals. These journals are available to logged-in ICAEW members, ACA students and other entitled users subject to suppliers' terms of use.
Exclusive
The Basel regulation's TP implications for banking institutions
- Article
- Sep 2024
- Ralf Heussner, Aaron Lee
Ralf Heussner of Deloitte Japan and Aaron Lee of Deloitte Singapore examine the latest transfer pricing trends impacting the banking sector in view of the implementation of the new Basel accord from 2025.
Exclusive
Amount B: implications for global industrial products and construction enterprises
- Article
- Sep 2024
- Claudia Lauten, Janis Sussick, Karen Smolka
Claudia Lauten, Janis Sussick, and Karen Smolka of Deloitte discuss how amount B could impact the tax and transfer pricing approaches of global multinational enterprises in the industrial products and construction sector.
Exclusive
France: new transfer pricing statutory provisions
- Article
- Sep 2024
- Bruno Gouthière
A summary of recent amendments to France's transfer pricing regulations, which aim to increase tax revenue through stricter documentation and compliance measures.
Exclusive
Pillar two necessary to boost tax revenues: Australian minister
- Article
- Aug 2024
Andrew Leigh tells ITR that the 15% minimum corporate tax is crucial to extracting revenue from multinationals that are misusing transfer pricing rules.
Exclusive
OECD releases list of 'covered' jurisdictions under amount B
- Article
- Jul 2024
Argentina, Brazil, Mexico and South Africa are among the countries the OECD believes could benefit from the simplified TP rules.
Exclusive
Price it right: the importance of cost accounting for intragroup services
- Article
- Jun 2024
- Enrique Marchesi-Herce, Gilles Andreini, Serena Picariello
Multinational enterprises must include transfer pricing and cost accounting experts in taking an integrated approach to supporting the arm's-length nature of intragroup service charges, say Enrique Marchesi-Herce, Gilles Andreini, and Serena Picariello of Deloitte Luxembourg.
Exclusive
AI and transfer pricing: a perfect partnership?
- Article
- Jun 2024
- Hank Moonen
AI will speed up some of the most laborious TP processes without making human input redundant, argues Hank Moonen, CEO of TaxModel.
Exclusive
Remove TP loopholes to prevent Russian oil profits, groups argue
- Article
- Jun 2024
Authorities must ensure that Russian firms do not use transfer pricing schemes to increase profits made from oil sold in different markets, advocacy organisations have argued.
Articles and books in the ICAEW Library collection
The collection of the ICAEW Library & Information Service includes a range of articles, books and reports on transfer pricing. A selection of books on this topic is set out below.
Tolley's international tax planning, 2023-24
- Library book
- 2023
- A. Seidler, I. Butt, D. Nott
- LexisNexis
This book sets the UK tax system in the context of international treaties and the international legal framework, examining issues such as permanent establishment, hybrids, EU law, thin capitalisation, interest deductions, withholding taxes, transfer pricing and information exchange. It includes a summary of the OECD's work on Pillar One and Pillar Two, along with a detailed treatment of the UK's implementation of Pillar Two. Examples, tables and checklists are included to aid understanding.
Principles of international taxation, 9th ed.
- Library book
- 2023
- L. Oats
- Bloomsbury Professional
This book provides a clear introduction to international taxation. It covers policy, legal issues and planning points, primarily from the viewpoint of a multinational group of companies. Examples and diagrams are given throughout.
OECD transfer pricing guidelines for multinational enterprises and tax administrations, 2022
- Library book
- 2022
- Organization for Economic Cooperation and Development
- OECD Publishing
The OECD Transfer Pricing Guidelines provide guidance on the application of the 'arm’s length principle' for the valuation of cross-border transactions between associated enterprises.
Cost accounting: a managerial emphasis
- Library book
- 2018
- C.T. Hongren
- Pearson
This book focuses on how cost accounting helps managers make better decisions, with chapters on topics including activity-based costing, activity-based management, inventory costing, balanced scorecard, cost management, transfer pricing and performance measurement.
- View a list of all books in our collection on transfer pricing
- View a list of articles in our collection on transfer pricing
To find out how you can borrow books from the Library please see our guide to borrowing books.
You can obtain copies of articles or extracts of books and reports through our document supply service.
Representations
ICAEW publishes its responses to HMRC and government consultations on tax policy and practice as representations. See all tax representations.
ICAEW REP 32/19 - Addressing the tax challenges of the digitalised economy
- Representation
- 07 Mar 2019
- PDF (280kb)
A response dated 6 March 2019 to a consultation published by OECD on 13 February 2019.
ICAEW REP 26/19 - Digital services tax
- Representation
- 28 Feb 2019
- PDF (271kb)
A response dated 28 February 2019 to a consultation published by HMT and HMRC on 7 November 2018.
ICAEW REP 04/19 - Tax avoidance involving profit fragmentation in Finance (No.3) Bill 2017-19
- Regulations
- 03 Jan 2019
- PDF (291kb)
Text of briefing submitted on 3 January 2019 to MPs by ICAEW Tax Faculty on Clause 16 & Schedule 4.
ICAEW Rep 106/18
- Representation
- 31 Aug 2018
- PDF (306kb)
Avoidance involving profit fragmentation arrangements
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