Safe harbour shopping — the latest trends
The Organisation for Economic Co-operation and Development Council (OECD) has released a revised version on the use of safe harbours in its Transfer Pricing Guidelines. This is welcome news for taxpayers.
Very broadly, transfer pricing rules permit tax authorities to adjust, for tax purposes, the price paid for goods and services sold or supplied between associated persons when intra-group transactions are undertaken on a non-arm’s-length basis. The rules also cover intra-group debt and related interest. In general, the transfer pricing rules require that intra-group prices and the terms and conditions of intra-group transactions abide by the arm’s-length principle. In the absence of avoidance legislation, connected companies would be able to manipulate prices to create a tax advantage, for instance by setting prices in a way that would enable profits to be located in a more favourable tax jurisdiction.
The OECD is an international economic organisation of currently 34 member states founded to stimulate economic progress and world trade. Among other objectives, it seeks to identify best practice and to co-ordinate the domestic and international policies of its members. The OECD maintains guidelines on transfer pricing, an issue that is of obvious relevance in the international context…
If you are registered and logged in to the site, click on the link below to read the rest of the Walker Morris briefing. If not, please register or sign in with your details below.
Sign in or Register to continue reading this article
It's quick, easy and free!
It takes just 5 minutes to register. Answer a few simple questions and once completed you’ll have instant access.Register now
Why register to The Lawyer
In-depth, expert analysis into the stories behind the headlines from our leading team of journalists.
Identify the major players and business opportunities within a particular region through our series of free, special reports.
Receive your pick of The Lawyer's daily and weekly email newsletters, tailored by practice area, region and job function.
More relevant to you
To continue providing the best analysis, insight and news across the legal market we are collecting some information about who you are, what you do and where you work to improve The Lawyer and make it more relevant to you.
News from Walker Morris
News from The Lawyer
Briefings from Walker Morris
Civil litigation in recent years has been dominated by cases and commentary concerned with costs, court fees, procedure and proportionality.
Key points on a clarification of the remedies available for misrepresentation.
Analysis from The Lawyer
Which firms are cutting it in this era of slimline rosters, and who are the GC new brooms making clean sweeps? The Lawyer can reveal all
The law school war shows no signs of ending. But we have, perhaps, reached the end of the beginning.