Latest Expert Exchange Queries
sitemapHome | Registration | Job Portal for CA's | Expert Exchange | Currency Converter | Post Matrimonial Ads | Post Property Ads
 
 
News shortcuts: From the Courts | News Headlines | VAT (Value Added Tax) | Service Tax | Sales Tax | Placements & Empanelment | Various Acts & Rules | Latest Circulars | New Forms | Forex | Auditing | Direct Tax | Customs and Excise | ICAI | Corporate Law | Markets | Students | General | Indirect Tax | Mergers and Acquisitions | Continuing Prof. Edu. | Budget Extravaganza | Transfer Pricing
 
 
 
 
Popular Search: TDS :: empanelment :: form 3cd :: articles on VAT and GST in India :: VAT Audit :: ICAI offer Get Windows 7,Office 2010 in Rs.799 Taxes :: ARTICLES ON INPUT TAX CREDIT IN VAT :: list of goods taxed at 4% :: ACCOUNTING STANDARDS :: Central Excise rule to resale the machines to a new company :: cpt :: TAX RATES - GOODS TAXABLE @ 4% :: VAT RATES :: ACCOUNTING STANDARD :: due date for vat payment
 
 
Transfer Pricing »
 HMRC steps up inquiries into cross-border deals by big business
 An Overview of Transfer Pricing in China
 South Africa: transfer pricing record-keeping rules finalized
 India among the top three nations where transfer pricing policies faced official examination: EY Survey
 Vietnam publishes draft transfer pricing law to combat tax avoidance
 New transfer pricing documentation rules and fiscal assessment procedure in Finland
 India, US resolve tax disputes worth Rs 5,000 crore via APA
 India, UK sign three Advance Pricing Agreements
  Foreign Exchange Management (Insurance) Regulations, 2015
 Why so many MNC offices are led by expats in India
 Govt looks to resolve 100 transfer pricing agreements by March next year

Transfer pricing changes proposed to address financial benefit due to incorrect pricing
May, 27th 2016

The government is consulting on the introduction of a secondary adjustment rule into the UK’s transfer pricing legislation, probing questions around whether such a rule would address the financial benefit arising from incorrect pricing within transfer pricing arrangements, which remains after application of the current rules

HMRC says the introduction of the secondary adjustment rule would complement the government’s work to date, both domestically and internationally, in tackling taxpayers entering into aggressive transfer pricing arrangements to avoid tax in the UK.

The suggested changes follow on from governmental efforts to address tax planning and relates to the UK’s role in the OECD/G20 effort to tackle Base Erosion and Profit Shifting. It was also included among the early action points which were expected to target aggressive transfer pricing practices by multinationals.

The arm’s length principle has been adopted internationally for transfer pricing rules. It provides an agreed basis for the fair allocation of profit on cross border transactions between connected parties and also avoids double taxation.

However, this also means that changes to that principle need the same international agreement and can take some time to agree.

The UK’s transfer pricing rules calculate the taxable profits on the price that would have been charged at arm’s length. This is achieved via an adjustment (the primary adjustment) to the price that is effective for tax purposes.

As the primary adjustment is only effective for tax purposes, any cash benefit from non-arm’s length pricing can accumulate in an overseas company, often located in a low tax country.

But a secondary adjustment rule would counter this.

HMRC says the rules are already an internationally recognised approach, part of transfer pricing rules applied in several leading jurisdictions including the US, Canada, France and EU member states.

 
 
Home | About Us | Terms and Conditions | Contact Us
Copyright 2016 CAinINDIA All Right Reserved.
Designed and Developed by Binarysoft Technologies Pvt. Ltd.
Binarysoft Technologies - Achievements

Transfer Pricing | International Taxation | Business Consulting | Corporate Compliance and Consulting | Assurance and Risk Advisory | Indirect Taxes | Direct Taxes | Transaction Advisory | Regular Compliance and Reporting | Tax Assessments | International Taxation Advisory | Capital Structuring | Withholding tax advisory | Expatriate Tax Reporting | Litigation | Badges | Club Badges | Seals | Military Insignias | Emblems | Family Crest | Software Development India | Software Development Company | SEO Company | Web Application Development | MLM Software | MLM Solutions