The Impact of OECD Developments on Transfer Pricing in the UK
1 September 2008
By Dr. Graham Poole
In this article from Euromoney Yearbooks' Transfer Pricing Review, NERA Associate Director Dr. Graham Poole examines a range of recent OECD developments and their implications for transfer pricing in the UK and potentially elsewhere. Dr. Poole addresses a number of current hot topics, including comparability analyses, use of profit-based methods, and the attribution of profits to permanent establishment, and notes that methodological developments prompted by the OECD will allow Her Majesty's Revenue & Customs to challenge the way transfer pricing is conducted in the UK and push for greater analytical rigor and sophistication. If it succeeds in doing so, Dr. Poole argues, then taxpayers and practitioners will be forced to look beyond one-sided and formulaic approaches and delve more deeply into the economics of how independent companies behave and how businesses operate and compete to create value.
