Shiv Mahalingham Published in International Tax Review: Uncertain Times for the UK

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Shiv Mahalingham, a managing director in Duff & Phelps European transfer pricing practice, provides a roundup of the key changes to the UK transfer pricing landscape in recent months.

In recent months, there have been some important changes to the UK transfer pricing governance process:

1. Revised HMRC inspector guidance confirming that where a transfer pricing issue is neither suitable for an advance pricing agreement (APA), nor does it warrant an inquiry, Inspectors should not engage with the customer in discussions on that issue.

2. Revised APA statement of practice confirming the preference for multilateral APAs in most situations.
   Initial experience of this revised process has shown that it is hampering the ability for businesses operating in the UK to obtain transfer pricing certainty and that it is leading to escalating transfer pricing compliance costs – particularly at year-end audit sign-off.