Book contents
- Frontmatter
- Contents
- List of figures
- List of tables
- List of contributors
- Acknowledgements
- The Golden Bridge: analytical table of cases by topics in the OECD Guidelines
- Table of Cases
- Abbreviations
- Part I The context of transfer pricing disputes
- Part II North America and Europe
- 3 Transfer pricing disputes in the United States
- 4 Transfer pricing disputes in Canada
- 5 Transfer pricing disputes in the European Union
- 6 Transfer pricing in Germany
- 7 Transfer pricing in Spain
- 8 Transfer pricing disputes in the United Kingdom
- Part III Asia Pacific
- Part IV BRIC Countries
- Part V South America, Middle East and Africa
- Part VI Conclusion
- Index
- References
8 - Transfer pricing disputes in the United Kingdom
from Part II - North America and Europe
Published online by Cambridge University Press: 05 November 2014
By
Book contents
- Frontmatter
- Contents
- List of figures
- List of tables
- List of contributors
- Acknowledgements
- The Golden Bridge: analytical table of cases by topics in the OECD Guidelines
- Table of Cases
- Abbreviations
- Part I The context of transfer pricing disputes
- Part II North America and Europe
- 3 Transfer pricing disputes in the United States
- 4 Transfer pricing disputes in Canada
- 5 Transfer pricing disputes in the European Union
- 6 Transfer pricing in Germany
- 7 Transfer pricing in Spain
- 8 Transfer pricing disputes in the United Kingdom
- Part III Asia Pacific
- Part IV BRIC Countries
- Part V South America, Middle East and Africa
- Part VI Conclusion
- Index
- References
Summary
Introduction
The experience of the United Kingdom in transfer pricing disputes is striking. On the one hand, due to the age of its income tax system, the United Kingdom has some of the earliest legislation that can be seen to have been addressed against transfer pricing. On the other hand, despite now having very modern legislation on transfer pricing, there are very few recorded transfer pricing disputes. Until the introduction of the modern rules in 1999, this appears to have been due to the strong administrative role played by the Inland Revenue as the tax authority at the time.
To some extent, a similar attitude, accepting administrative contacts as the appropriate means to resolve transfer pricing disputes, appears to have persisted since then. However, there are signs that taxpayers are now more willing to litigate transfer pricing disputes, although it seems that cases are still mostly resolved before any judicial hearing.
- Type
- Chapter
- Information
- Resolving Transfer Pricing DisputesA Global Analysis, pp. 303 - 356Publisher: Cambridge University PressPrint publication year: 2012
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