Dealing with double taxation

Aude Delechat-Patel and Paula Ruffell provide guidance on achieving relief from transfer pricing double taxation

One of the important changes for international tax practitioners is an increase in enquiries over transfer pricing issues – especially into a group’s transfer pricing policies. Many of these enquiries follow the changes to the OECD Transfer Pricing guidelines (and those from the UN), mandated by the Base Erosion and Profit Sharing (BEPS) Inclusive Framework. This trend is likely to continue as the changes agreed in October 2015 make their way into general practice globally. This view is supported by HMRC’s recent launch of the Profit Diversion Compliance Facility, which sets HMRC’s sights not only on large businesses, but also the mid-market.