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| The right transfer pricing documentation (PDF, 136 KB) An appropriately developed transfer pricing strategy helps multinationals to optimise their tax position, manage their tax risks and reduce time spent on compliance while, at the same time, ensuring that intercompany pricing policies are consistent with the overall business objectives. Read more on how compliance can be turned in a value added process. |
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Paying the right amount for using your parent’s name (PDF, 104 KB) The transfer pricing analysis of a brand licence does not necessarily assign all the brand value to the party that holds the registration of the trade marks associated with the brand. In this article we review the relevant UK transfer pricing legislation and the position of tax and commercial case law supporting this proposition. |
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Centralised IP structures: Substance requirement (PDF, 164 KB) In the early 1990s the first businesses transformed corporate efficiency and profitability through taking a holistic business view and optimising their supply chain networks – the complex web of suppliers, production and R&D facilities, distribution centres, sales subsidiaries, channel partners and customers. Typically the best commercial structure involved a centralisation of regional activity into a ‘Principal’ company. Today most multinationals make more significant profits from ideas leading to products as opposed to the act of making products themselves. |
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