Feature and articles
UK international tax reform on the horizon?
- Article
- 23 Jan 2024
There is broad support for measures to reform the transfer pricing, permanent establishment and diverted profits tax rules.
DPT, transfer pricing and permanent establishment reforms: ICAEW responds
- Article
- 22 Aug 2023
ICAEW’s Tax Faculty welcomed HMRC proposals to make the UK legislation more closely aligned with OECD principles, but noted that there were good reasons to not fully adopt the OECD’s 2017 changes to the permanent establishment definition.
Tax news in brief 26 July 2023
- Article
- 25 Jul 2023
Highlights from the broader tax news for the week ending 26 July 2023, including: corporation tax filing for companies in insolvency; relief for foreign taxes in PAYE codes; HMRC guidance on negative earnings; and transfer pricing records regulations.
UK international tax legislation to be reformed
- Article
- 29 Jun 2023
The UK government is seeking views on reforming the UK rules on transfer pricing, permanent establishments, and diverted profits tax.
Draft Finance Bill 2022-23: enactment of OECD rules into UK law
- Article
- 22 Jul 2022
The draft legislation, announced on 20 July, includes the introduction of a top-up tax applicable to multinational business alongside changes to the UK transfer pricing documentation requirements.
The impact of work-from-anywhere policies
- Article
- 29 Jul 2021
What effect does a globally mobile workforce have on transfer pricing arrangements?
Transfer pricing documentation requirements to be made more robust
- Article
- 24 Mar 2021
Tougher requirements for transfer pricing documentation will better focus compliance interventions and bring more alignment with international approaches, according to HMRC. ICAEW’s Tax Faculty outlines a new consultation on updating rules.
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Transfer pricing and the COVID-19 pandemic
- Article
- 31 Jul 2020
Jonathan Schwarz of Temple Tax Chambers takes an in-depth look at why businesses might need to review their pricing arrangements in light of the global COVID-19 pandemic, including key practical takeaways.
Bloomsbury Accounting and Tax Service
Eligible firms have free access to Bloomsbury Professional's comprehensive online library, comprising around 80 titles from some of the country's leading tax and accounting subject matter experts. Find out who is eligible and how you can access the Accounting and Tax Service.
Exclusive
Transfer pricing
- eBook chapter
- 2024
- Satwaki Chanda, Steve Collings, Jacquelyn Kimber, Maria Kitt, David O'Keefe, Andrew Parkes
- Corporation Tax
A full chapter providing practical guidance on transfer pricing, including the OECD BEPS project and the UK transfer pricing rules.
Exclusive
Global transfer pricing: principles and practice (fifth edition)
- eBook
- 2023
- Roy Donegan
- Global Transfer Pricing - Principles and Practice
Accessible introduction to transfer pricing – a complex and increasingly important area of business taxation.
Exclusive
Transfer pricing administration
- eBook chapter
- 2023
- Lynne Oats
- Principles of International Taxation
A chapter on transfer pricing administration, covering the documentation requirements before looking at dispute resolution, the penalties that can apply in transfer pricing cases and finally, the use of advanced pricing arrangements and other forms of cooperation.
Exclusive
Transfer pricing practice
- eBook chapter
- 2023
- Lynne Oats
- Principles of International Taxation
A chapter on transfer pricing, providing an introduction to its key principles, OECD guidelines, transfer pricing methods and the Arm's Length Principle.
Terms of use
You are permitted to access, download, copy, or print out content from eBooks for your own research or study only, subject to the Acceptable usage terms.
The Library & Information Service provides a collection of eBooks as a benefit of membership. Please log in to access these titles. If you are unable to access an eBook, please see our Help and support or contact library@icaew.com.
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Transfer pricing in relation to businesses in economic and financial distress
- eBook chapter
- 2023
- Raffaele Petruzzi, Abhishek Padwalkar
- IBFD Publications USA
A chapter examining the challenges which may arise in the performance of transfer pricing analysis and the application of transfer pricing rules in times of economic instability. The authors make some suggestions as to how such challenges might be successfully navigated.
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Anti-avoidance
- eBook chapter
- 2023
- IBFD
- IBFD
- Global Corporate Tax Handbook
A section providing an overview of the UK's anti-avoidance rules relating to corporate taxation. Covers the general anti-abuse rule (GAAR), disclosure of tax avoidance schemes (DOTAS) rules, Pillar Two, transfer pricing legislation, limitations on interest deductibility, the controlled foreign company (CFC) charge, and the legislation on hybrid mismatches.
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Compliance issues and transfer pricing disputes
- eBook chapter
- 2022
- Jerome Monsenego
- Wolters Kluwer
A chapter examining two administrative concerns linked to transfer pricing: the need to enforce certain compliance rules, and the prevention and resolution of cross-border transfer pricing disputes.
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Introduction to transfer pricing
- eBook
- 2022
- Jerome Monsenego
- Wolters Kluwer
Illustrates the fundamentals of transfer pricing with examples based on the business models used by multinational enterprises. Includes relevant court cases from various countries.
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Anti-avoidance
- eBook chapter
- 2021
- Malcolm James
- Spiramus
- UK Tax System - An Introduction
A chapter summarising HMRC's present strategy with regard to tax avoidance. Includes an overview of the various rules and legislation in this area.
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Fundamentals of transfer pricing: general topics and specific transactions
- eBook
- 2021
- Michael Lang, Giammarco Cotani, Raffaele Petruzzi
- Wolters Kluwer Law International
This guide explores the practical application of transfer pricing rules, offering examples and international judicial precedents. Chapters cover transfer pricing methods, approaches to prevent and resolve disputes, documentation, attribution of profits to permanent establishments, and specific transactions (such as services, financing, intangibles and business restructurings).
Terms of use
You are permitted to access, download, copy, or print out content from eBooks for your own research or study only, subject to the terms of use set by our suppliers and any restrictions imposed by individual publishers. Please see individual supplier pages for full terms of use.
Industry press
The ICAEW Library & Information Service provides access to a range of leading tax journals. These journals are available to logged-in ICAEW members, ACA students and other entitled users subject to suppliers' terms of use.
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IRS TP memorandum 'leaves more questions than answers'
- Article
- Mar 2024
The US tax agency's advice is consistent with OECD guidance and shouldn't surprise anyone, other experts tell ITR.
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Understanding the TP audit cycle in Egypt part one
- Article
- Mar 2024
- Yasmine Hammad, Haidy Elaasser, and Mahmoud Ashraf
In the first article of a two-part series on transfer pricing audits in Egypt, Yasmine Hammad, Haidy Elaasser, and Mahmoud Ashraf of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt explain the current process.
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Understanding the TP audit cycle in Egypt – part two
- Article
- Mar 2024
- Yasmine Hammad, Haidy Elaasser, and Mahmoud Ashraf
Yasmine Hammad, Haidy Elaasser, and Mahmoud Ashraf of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt conclude a two-part series on transfer pricing audits in Egypt by anticipating the changes under the newly established automated process.
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Indonesia: New TP implementation rules and a revised WHT framework
- Article
- Mar 2024
- Fabian Abi Cakra and Danang Syailendra
Fabian Abi Cakra and Danang Syailendra of GNV Consulting explain how several Indonesian transfer pricing regulations have been combined into new legislation, and summarise changes to employee income tax under a withholding tax regulation.
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Shortened deadline for drafting TP documentation in Italy
- Article
- Feb 2024
- Federico Vincenti and Carola Valente
Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente explain the revised timeframes and requirements for Italian taxpayers submitting transfer pricing documentation and aiming to benefit from the penalty protection regime.
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Performing year-end TP adjustments in China
- Article
- Feb 2024
- Lewis Lu and Xiaoyue Wang
Lewis Lu and Xiaoyue Wang of KPMG China consider issues with conducting year-end transfer pricing adjustments in China.
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Pillars one and two: TP considerations for jurisdictions and MNEs
- Article
- Feb 2024
- Sanjay Kumar, Suchint Majumdar
Sanjay Kumar and Suchint Majumdar of Deloitte India provide a guide to the BEPS package and explain why streamlining the calculation of amounts A and B is integral to its successful implementation.
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Arming your transfer pricing arsenal: essential evidence for tax-proof documentation
- Article
- Feb 2024
- Nouran Ibrahim, Haidy Elaasser
Nouran Ibrahim and Haidy Elaasser of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt explain what supporting evidence should be kept in readiness for potential queries raised by the Egyptian Tax Authority at times of audit.
Articles and books in the ICAEW Library collection
The collection of the ICAEW Library & Information Service includes a range of articles, books and reports on transfer pricing. A selection of books on this topic is set out below.
Tolley's international tax planning, 2023-24
- Library book
- 2023
- A. Seidler, I. Butt, D. Nott
- LexisNexis
This book sets the UK tax system in the context of international treaties and the international legal framework, examining issues such as permanent establishment, hybrids, EU law, thin capitalisation, interest deductions, withholding taxes, transfer pricing and information exchange. It includes a summary of the OECD's work on Pillar One and Pillar Two, along with a detailed treatment of the UK's implementation of Pillar Two. Examples, tables and checklists are included to aid understanding.
Principles of international taxation, 9th ed.
- Library book
- 2023
- L. Oats
- Bloomsbury Professional
This book provides a clear introduction to international taxation. It covers policy, legal issues and planning points, primarily from the viewpoint of a multinational group of companies. Examples and diagrams are given throughout.
The Oxford handbook of international tax law
- Library book
- 2023
- F. Haase, G. Kofler (eds.)
- Oxford University Press
This handbook traces the history of international tax law from its earliest days until the present. It includes coverage of the key issues in this area today, including tax transparency, minimum corporate taxation, the tackling of Base Erosion and Profit Shifting (BEPS), and the reconstruction of the network of bilateral tax treaties.
OECD transfer pricing guidelines for multinational enterprises and tax administrations, 2022
- Library book
- 2022
- Organization for Economic Cooperation and Development
- OECD Publishing
The OECD Transfer Pricing Guidelines provide guidance on the application of the 'arm’s length principle' for the valuation of cross-border transactions between associated enterprises.
Cost accounting: a managerial emphasis
- Library book
- 2018
- C.T. Hongren
- Pearson
This book focuses on how cost accounting helps managers make better decisions, with chapters on topics including activity-based costing, activity-based management, inventory costing, balanced scorecard, cost management, transfer pricing and performance measurement.
- View a list of all books in our collection on transfer pricing
- View a list of articles in our collection on transfer pricing
To find out how you can borrow books from the Library please see our guide to borrowing books.
You can obtain copies of articles or extracts of books and reports through our document supply service.
Representations
ICAEW publishes its responses to HMRC and government consultations on tax policy and practice as representations. See all tax representations.
ICAEW REP 32/19 - Addressing the tax challenges of the digitalised economy
- Representation
- 07 Mar 2019
- PDF (280kb)
A response dated 6 March 2019 to a consultation published by OECD on 13 February 2019.
ICAEW REP 26/19 - Digital services tax
- Representation
- 28 Feb 2019
- PDF (271kb)
A response dated 28 February 2019 to a consultation published by HMT and HMRC on 7 November 2018.
ICAEW REP 04/19 - Tax avoidance involving profit fragmentation in Finance (No.3) Bill 2017-19
- Regulations
- 03 Jan 2019
- PDF (291kb)
Text of briefing submitted on 3 January 2019 to MPs by ICAEW Tax Faculty on Clause 16 & Schedule 4.
ICAEW Rep 106/18
- Representation
- 31 Aug 2018
- PDF (306kb)
Avoidance involving profit fragmentation arrangements
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