IDEAS home Printed from https://ideas.repec.org/h/spr/sprchp/978-3-319-73332-6_41.html
   My bibliography  Save this book chapter

United Kingdom

In: Intangibles in the World of Transfer Pricing

Author

Listed:
  • John Henshall

    (Deloitte)

  • Daniela Griese

    (Deloitte)

  • Phil Henderson

    (Deloitte)

  • Shaun Austin

    (Deloitte)

Abstract

The UK transfer pricing legislation, which can be found in the Taxation (International and Other Provisions) Act 2010 (“TIOPA 2010”), Part 4, requires that any provision made by a transaction (or series of transactions) between connected persons be made on an arm’s length basis, as would have been made between independent enterprises. The legislation does not directly stipulate how the arm’s length provision should be established and instead requires that it “be read in such manner as best secures consistency” with the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“OECD Guidelines”) and the OECD Model Tax Convention on Income and on Capital, as covered in other chapters. At the time of writing, the 2017 version of the OECD Guidelines, published by the OECD on July 10, 2017, should be used for interpreting UK transfer pricing (“TP”) laws. This includes the approach to the transfer pricing of hard-to-value intangibles (“HTVI”) that is contained in the OECD Transfer Pricing Guidelines, Chapter VI Section D.4.

Suggested Citation

  • John Henshall & Daniela Griese & Phil Henderson & Shaun Austin, 2021. "United Kingdom," Springer Books, in: Björn Heidecke & Marc C. Hübscher & Richard Schmidtke & Martin Schmitt (ed.), Intangibles in the World of Transfer Pricing, edition 1, pages 603-619, Springer.
    • Handle: RePEc:spr:sprchp:978-3-319-73332-6_41
    DOI: 10.1007/978-3-319-73332-6_41
    as

    Download full text from publisher

    To our knowledge, this item is not available for download. To find whether it is available, there are three options:
    1. Check below whether another version of this item is available online.
    2. Check on the provider's web page whether it is in fact available.
    3. Perform a search for a similarly titled item that would be available.

    More about this item

    Statistics

    Access and download statistics

    Corrections

    All material on this site has been provided by the respective publishers and authors. You can help correct errors and omissions. When requesting a correction, please mention this item's handle: RePEc:spr:sprchp:978-3-319-73332-6_41. See general information about how to correct material in RePEc.

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    We have no bibliographic references for this item. You can help adding them by using this form .

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your RePEc Author Service profile, as there may be some citations waiting for confirmation.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: Sonal Shukla or Springer Nature Abstracting and Indexing (email available below). General contact details of provider: http://www.springer.com .

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    IDEAS is a RePEc service. RePEc uses bibliographic data supplied by the respective publishers.