Joel Cooper

Joel Cooper

Joel Cooper is an EY Partner and the EY Global International Tax and Transaction Services Controversy Leader. He advises clients from a range of industries on preparing for and managing cross-border tax controversy. He has extensive experience in assisting clients with advance pricing agreements, mutual agreement procedures, settlement strategy and preparation for litigation.

UK transfer pricing section 147: the arm's length principle
21 October 2022

This article considers the operation of TIOPA 2010 s 147 in UK transfer pricing enquiries and questions the validity of the common use of the interquartile range and transfer pricing adjustments made ‘within the range’.