Transfer pricing

Feature and articles

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.

Tax news in brief

Article
18 Dec 2020

Highlights from the broader tax news week ending 22 December, which includes: guidance from HMRC on disguised remuneration schemes that avoid tax by selling business revenues to trusts, changes to land transaction tax and Royal Assent of the Taxation (Post-transition Period) Bill 2020.

Exclusive 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 more than 60 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 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.

Exclusive Transfer pricing

eBook chapter
2023
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.

Terms of use

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eBooks

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.

Exclusive 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.

Exclusive 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.

Exclusive 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.

Exclusive 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.

Exclusive 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.

Exclusive 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.

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.

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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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