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Articles by Phil Roper
Do Mobile Workers Create Permanent Establishment, TP Challenges?
Global mobility frequently appears as a potential area of concern for transfer pricing professionals. For example, executives may be told to avoid signing contracts in foreign jurisdictions because doing so might create a permanent establishment, or PE.
OECD consultation on intra-group services: incremental change, persistent uncertainty
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How Countries Stack Up in OECD’s 2024 APA Statistics Report Original
In October, the OECD released its annual Advance Pricing Agreement and Mutual Agreement Procedure Statistics for 2024. These statistics contain a wealth of information on the relative success of different countries’ APA and MAP programs and provide insight into the effectiveness of different bilateral relationships. For businesses considering how to manage transfer pricing risk in different countries, the statistics are a key—though often still underutilized—tool.
Get the FOTRA out of the UK!
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The new non-dom rules
The new rules for non-doms have a surprisingly advantageous effect for some people. There are a significant number of people who were born in the UK with a UK domicile of origin and who later acquired a foreign domicile of choice. Under the old rules, if they become UK resident they were immediately deemed domiciled in the UK – although there was a one-year period of grace for IHT.
Meet in the middle: HMRC’s transfer pricing settlement policy
HMRC have issued new advice to their compliance teams and governance boards on settling transfer pricing (TP) enquiries where HMRC consider that a taxpayer’s filed position is outside the arm’s length range and relief from double taxation is available by treaty under the Mutual Agreement Procedure (MAP). In such cases, the default position will be for HMRC to adjust to a central point in the range (for example, the median in the set of comparables used to establish the arm’s length range).
Uber London Ltd v HMRC
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Fiscal drag and the additional rate of income tax
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HMRC change of policy: VAT on insurance intermediary services
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HMRC raise the stakes on diverted profits investigation
HMRC have published their latest annual Transfer Pricing (TP) and Diverted Profits Tax (DPT) statistics which cover the year ended 31 March 2024 (FY23-24). The statistics show HMRC continue to be very active on transfer pricing initiatives with the headline TP yield number increasing to £1.79 billion (up from £1.64 billion in FY22-23), the second highest yield reported over the past six years.
Amount B update: US all in (for now) but early signs of
As 2024 drew to a close there were some important developments on Amount B, the OECD’s recommended simplified and streamlined approach to transfer pricing for ‘baseline’ marketing and distribution activities (referred to as the SSA). The SSA is intended to reduce transfer pricing disputes and compliance costs for businesses and tax authorities and has been designed with a specific focus on the needs of low-capacity jurisdictions.
KPMG Picks Its 2023 Advance Pricing Agreement Award Winners Original
On November 15, 2024, the OECD, released, for the first time ever, country-specific advance pricing agreement (APA) statistics as part of its annual Tax Certainty Day – an event that included the bestowing of mutual agreement procedure (MAP) and APA awardsfor jurisdictions with notable achievements in the field of tax certainty.
The OECD has published 2023 statistics for MAP and, for
The OECD has published 2023 statistics for MAP and, for the first time, statistics for APAs The OECD has published 2023 statistics for MAP and, for the first time, statistics for APA KPMG in the UK › Insights › Prevention and cure: the OECD’s APA and MAP statistics On 15 November 2024, the OECD held its sixth annual Tax Certainty Day, which also saw the publication of Mutual Agreement Procedure (MAP) and Advance Pricing Agreement (APA) statistics for 2023.
Agree the B
Get the latest KPMG thought leadership directly to your individual personalised dashboard The OECD has published a Model Competent Authority Agreement for countries to implement ‘Amount B’ of BEPS 2.0 OECD publishes a Model Competent Authority Agreement for countries to implement ‘Amount B On 26 September 2024, the OECD/G20 Inclusive Framework on BEPS (IF) published a Model Competent Authority Agreement (MCAA) on the application of ‘Amount B’.
Mortar in the Cracks: New Amount B Guidance
In February 2024, the OECD/G20 Inclusive Framework on BEPS (“Inclusive Framework”) published the final Amount B guidance in an agreed consensus document, with reservations from India.
Share based reward: the transfer pricing cost conundrum
Get the latest KPMG thought leadership directly to your individual personalised dashboard Irish Tax Appeals Commission rules taxpayer correct to exclude notional cost of shares from intra-group service fee cost base Transfer pricing treatment of share based compensation KPMG in the UK › Insights › Share based reward: the transfer pricing cost conundrum This case was the first determination by the Tax Appeals Commission (TAC) in Ireland on a transfer pricing matter.
HMRC’s new transfer pricing guidance on risk and reward
Home > Articles > HMRC’s new transfer pricing guidance on risk and reward HMRC’s new transfer pricing guidance on risk and reward © Copyright LexisNexis 2024. All rights reserved. 14 March 2024 Speed read New transfer pricing guidance issued by HMRC reinforces the importance of granular analysis of control of economically significant risks when designing and documenting transfer pricing policies for UK entities.
HMRC Guidance: A New Transfer Pricing Risk to Control
Transfer pricing does not get much more complex than the control of risk framework — which different tax authorities interpret in different ways. But the punchline of new guidance, published by HMRC is simple: where businesses have senior personnel in the UK and those personnel are responsible for making decisions about key business risks, they should be thinking about what implications recent HMRC guidance has for their transfer pricing policies.
Control of Risk: A New Transfer Pricing Risk to Control Original
Transfer pricing does not get much more complex than the control of risk framework — which different tax authorities interpret in different ways. But the punchline of new guidance, published by HMRC is simple: where businesses have senior personnel in the UK and those personnel are responsible for making decisions about key business risks, they should be thinking about what implications recent HMRC guidance has for their transfer pricing policies.
Transfer Pricing Takeaways from 2022’s MAP Statistics Original
The Organisation for Economic Cooperation and Development (OECD) on November 15, 2023, released the latest Mutual Agreement Procedure (MAP) statistics and awardsfor the calendar year ended December 31, 2022, that highlight important takeaways for multinational enterprises.
UK Consults on Wide Reforms of International Tax Legislation
The UK tax authority, HM Revenue & Customs, recently published an ambitious and wide-ranging stakeholder consultation on reforming the UK’s legislation on transfer pricing, permanent establishment, and diverted profits tax. This triumvirate of international tax rules is the primary means on which the UK’s claims to tax the profits earned by multinational enterprises have been based.
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