OTR90050 - Orchestra Tax Relief: Avoidance: Transfer pricing
Part 4 Taxation (International and Other Provisions) Act 2010
In applying transfer pricing rules, the UK observes the Transfer Pricing Guidelines issued by the OECD (바카라 사이트˜Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, Organisation for Economic Co-operation and Development, Paris, 1995바카라 사이트™). Such rules apply to orchestral concerts as they do to any other sector of the economy.
Paragraph 1.55 of the OECD guidelines addresses the impact of 바카라 사이트 policies when determining the transfer price of transactions between connected parties. They make clear that such 바카라 사이트 interventions should be treated as conditions of the market which should be taken into account in evaluating the transfer price. Once this has been done, the question arises whether, in the light of these conditions, the transactions undertaken by the connected parties are consistent with transactions between independent enterprises.