For further information on this topic, please contact Catherine Hiriart-Durruthy (chd@pftp-transferpricing.com)

October 2006
Client Newsletter - Autumn 2006

For a copy of our latest newsletter, please contact Catherine Hiriart-Durruthy (chd@pftp-transferpricing.com) or send us a request via our Contact page here.

February 2006
Client Newsletter - Winter 2006

Click here, to see our latest newsletter.

January 2006
EU Report on documentation Requirements

Click here, to see the final report from the EU's Joint Transfer Pricing Forum concerning transfer pricing documentation requirements.

We are currently in the process of updating our website, so please bear with us.

United Kingdom: August 2004
Finance Bill 2004 receives Royal Assent and introduces new Transfer Pricing rules

Despite the fact that the Finance Bill only received Royal Assent on 22 July 2004, the new transfer pricing rules became effective on 1 April 2004.  As discussed below and in our special newsletter on the topic, the changes to the legislation are wide ranging and affect all inter-company transactions, including UK to UK.

At the time of the 2004 Budget, the Inland Revenue undertook to produce guidance notes to assist taxpayers with the changes.  Links to the draft guidance, issued by the Inland Revenue, can now be found by clicking here

Guidance can be found on a number of topics, including :

Documentation

Small & Medium sized businesses

Compensating Adjustments

Thin Capitalisation

Centrally Provided Services

A large number of companies will be faced with a not inconsiderable amount of work, following the introduction of this legislation, and it is expected that the legislation will continue to be refined over the short term, as the government seeks to plug gaps and cover areas not addressed, and this is not to mention the possible changes that may be required as a result of decisions taken by the European Court of Justice.

USA: August 2004
Applications for APA's

The IRS have issued a new procedure for taxpayers wishing to apply for an Advanced Pricing Agreement.  It supersedes all previous procedure issued on this topic.

Procedure for requesting an Advanced Pricing Agreement