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Many of our transfer pricing team are both economists and tax professionals and can provide expert advice on any aspect of transfer pricing including the following key areas:
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documentation – advice on the preparation of transfer pricing guidelines to comply with tax law and in accordance with the OECD guidelines.
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defence – in the event of a transfer pricing enquiry by the Inland Revenue, we advise on the strategy and technical approach to the investigation and can negotiate on our clients behalf.
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planning – we can provide comfort that a groups transfer pricing policies are appropriate for their operations. Our transfer pricing experts are experienced in Competent Authority negotiations and Advanced Pricing Agreement procedures and this may involve co-ordinating with our world-wide transfer pricing specialists.
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thin capitalisation – financing issues are of particular interest to the Inland Revenue, particularly in relation to levels of debt and interest payments. We can advise on preparing the necessary analysis to defend queries raised by the Inland Revenue in relation to the funding of UK entities within a world wide group.
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