![]() ![]() Cross-references to the relevant section of the Guidelines appear throughout this chapter. It is not a substitute for the Guidelines, which should always be referred to for further detail. This section of the guidance is an introduction to the transfer pricing methodologies set out in the Guidelines. Of necessity the Guidelines are written in very broad terms. However, the strict statutory position remains that the 2010 Guidelines apply for corporation tax purposes only to accounting periods beginning on or after 1 April 2011, and for income tax purposes for the tax year 2011-2012 and subsequent tax years in accordance with TIOPA10/S164(4) and FA11/S58 and the 2015 updates apply for corporation tax purposes only to accounting periods beginning on or after 1 April 2016, and for income tax purposes for the tax year 2016-2017 and subsequent tax years in accordance with FA16/S75 and the 2017 Guidelines for corporation tax purposes only to accounting periods beginning on or after 1 April 2018 and for income tax purposes for the tax year 2018-19 and subsequent tax years in accordance with Statutory Instrument 2018/266.Įxcept where otherwise stated, references in these instructions to paragraphs within the OECD Transfer Pricing Guidelines are to the 2017 version. The 2015 updates contain additional guidance on comparability analyses including, in particular, comparability analyses and accurate delineation of the controlled transaction ( INTM485020 onwards) the use of quoted prices for commodity transactions ( INTM421041) intangibles ( INTM440110 onwards), intra-group services ( INTM440060 onwards), and cost contribution arrangements ( INTM421090). It will therefore be useful and informative to refer to them with regard to any accounting periods under consideration. The 2010 Guidelines contain considerably expanded practical guidance on carrying out comparability analyses and the application of the transactional profit methods (see INTM421020 and INTM421070 to INTM421080). ![]() It is anticipated that in the vast majority of cases the application of any version should result in the same outcome given that the fundamental purpose of all is to provide guidance to assist in confirming or establishing the arm’s length price for the tested transaction. For corporation tax accounting periods beginning on or after 1 April 2018 or income tax years 2018-19 or later, the Transfer Pricing Guidelines approved by the OECD on 10 July 2017 (‘the 2017 Guidelines’).For corporation tax accounting periods beginning on or after 1 April 2011 or income tax years 2011-2012 or later, the Transfer Pricing Guidelines approved by the OECD on 22 July 2010 (‘the 2010 Guidelines’).įor corporation tax accounting periods beginning on or after 1 April 2016 or income tax years 2016-17 or later, the Transfer Pricing Guidelines approved by the OECD on 22 July 2010 (‘the 2010 Guidelines’) as amended by the BEPS Final Report on Actions 8-10 published by OECD on 5 October 2015:.For corporation tax accounting periods beginning prior to 1 April 2011 or income tax years 2010-2011 or earlier, documents published by the OECD before (‘the 1995 Guidelines’). ![]() Reference to the OECD Transfer Pricing Guidelines means: Interpretation of transfer pricing legislation must be consistent with Article 9 (the ‘Associated Enterprises Article’) of the OECD MTC - see INTM420010 - and in accordance with the Transfer Pricing Guidelines. It is recommended reading for those embarking on a transfer pricing review.
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