INTM484030 - Transfer pricing: operational guidance: examining transfer pricing reports: legislation

Transfer pricing legislation

The report will usually contain an examination of the relevant transfer pricing legislation. This part of the report is often included solely for the client바카라 사이트™s benefit.

The report might also detail the legislation of other countries if the report was originally prepared for another fiscal authority. Suggestions such as that 바카라 사이트˜the UK legislation works along similar lines to this legislation바카라 사이트™ should be treated with caution; the scope of TIOPA10/Part 4 may go significantly beyond that of the other countries바카라 사이트™ legislation. For example, the US Section 482 transfer pricing legislation is different in some important ways from the UK legislation, in substance as well as form. Remember that the company바카라 사이트™s transfer pricing policy has to pass the test of UK legislation. It is not enough for UK transfer pricing purposes to show that the transfer pricing in the territory of the affiliate with which the UK company trades is arm바카라 사이트™s length for the purposes of that territory바카라 사이트™s transfer pricing legislation.