International Tax

Transfer Pricing: Rules and Practice in Selected Countries (T-Z) (Portfolio 6975)

  • In this Portfolio, our expert authors present the rules and practice related to transfer pricing in Taiwan and the United Kingdom.


The Transfer Pricing: Rules and Practice in Selected Countries (T–Z)Portfolio begins with a brief introduction of Taiwan, including a brief description of the history of Taiwan’s transfer pricing rules, then discusses the rules themselves, setting forth the principles for determining arm’s-length prices, the scope of transactions subject to the rules, applicable transfer pricing methods available for different types of transactions, and audits and penalties. These topics are followed by a discussion of disclosure, reporting, and documentation requirements, the burden of proof in a transfer pricing audit, and, finally, whether an appeal is available.

The Portfolio also analyzes the United Kingdom’s transfer pricing legislation in Part 4 of Taxation (International and Other Provisions) Act 2010 (TIOPA 2010), rules on advance pricing agreements (in Part 5 of TIOPA 2010), penalties and information powers (in Finance Act 2008), and rules on the application of the mutual agreement procedure (in Part 2 of TIOPA 2010). This chapter also considers relevant guidance provided by Her Majesty’s Revenue and Customs (HMRC) and relevant case law. Also considered is a framework for HMRC transfer pricing inquiries, including governance and review procedures, formalized by HMRC and overseen by the Transfer Pricing Group within HMRC.

Table of Contents

Portfolio 6975-1st: Transfer Pricing: Rules and Practice in Selected Countries (T-Z)

CHAPTER 170: TRANSFER PRICING RULES AND PRACTICE IN THE REPUBLIC OF CHINA (TAIWAN) by Michael Wong and Andrew Lee Baker & McKenzie Taipei, Republic of China

170:I. Introduction

170:II. Overview of Taiwan’s Tax System

170:III. History of Taiwan’s Transfer Pricing Rules

170:IV. Current Transfer Pricing Rules in Taiwan

170:V. Documentation and Disclosure Requirements

170:VI. Audit Practice

170:VII. Appeals

170:VIII. Penalties

170:IX. Resolving Conflicts with Other Countries

170:X. Adjustments to Be Made in the Wake of a Transfer Pricing Adjustment

170:XI. Advance Pricing Agreements

CHAPTER 175: TRANSFER PRICING RULES AND PRACTICE IN THE UNITED KINGDOM A revision by Jenny Cottrell Stephenson Harwood London, England  of a previous version by Steve Edge, Tax Specialist Tony Beare, Tax Specialist Bob Ramage, Tax Specialist Graham Earles, Tax Specialist Slaughter & May London, England

175:I. Introduction

175:II. Background: U.K. Corporation Tax

175:III. Overview of U.K. Transfer Pricing Law

175:IV. Disallowance of Trading Expenses

175:V. Sharkey v. Wernher and Associated Cases

175:VI. Double Taxation Treaty Provisions

175:VII. The Course of a Transfer Pricing Inquiry

175:VIII. The Arm’s Length Price

175:IX. Loans and Thin Capitalization

175:X. Advance Pricing Agreements

175:XI. Other Provisions

Andrew Cousins
Andrew Cousins
Duff & Phelps Ltd.
Dennis Lee
Tax Partner
Baker & McKenzie LLP
Michael Wong
Baker & McKenzie LLP
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