United Kingdom - Profit Shifting and the United Kingdom
- United Kingdom
- A. Casley; S. Wlazlowski; S. Wood
- International Transfer Pricing Journal, 2015 (Volume 22), No 1
- 30 January 2015
The Finance Bill 2014 enacted new legislation on so-called “profit transfers” and on certain other specific transactions. One thing that these have in common is that they may cut straight across the application of the arm’s length principle. Certainly, they have the potential to do so. This article looks at the background to these new rules, the rules themselves, and their potential application.