Transfer Pricing: Rules and Practice in Selected Countries (T-Z) (Portfolio 6975)
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In this Portfolio, our expert authors present the rules and practice related to transfer pricing in Taiwan and the United Kingdom.
Description
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
Director
Duff & Phelps Ltd.
Tax Partner
Baker & McKenzie LLP
Partner
Baker & McKenzie LLP