charges artificially low prices to, or is charged artificially high prices by, foreign affiliates. The transfer pricing regime is in line with OECD guidelines. It will broadly apply where the actual provisions in a transaction differ from the provisions which would have been made at arm’s length between independent enterprises as a result of which a potential advantage in relation to UK taxation is conferred. Transactions for this purpose are widely defined and include interest payments. This could lead to interest payments of thinly capitalised subsidiaries being disallowed as deductions in calculating taxable profits of the subsidiary. The Government has recently laid the Transfer Pricing Records Regulations 2023, which require large companies in scope of the regulations to keep detailed records of information relating to transfer pricing. Our firm Fladgate LLP, located in central London, is a law firm renowned for understanding and anticipating our clients’ risks and opportunities. We pride ourselves on being our clients’ true partners in business, with an unrivalled understanding of the worlds in which they operate. With enterprising and commercial legal thinking at its core, the firm specialises in providing a wide variety of highly personalised legal services for a portfolio of prestigious clients in the UK and across Europe, India, Israel, the Middle East, Asia Pacific, South Africa, and North America. With our multi-lingual and multi-qualified lawyers, Fladgate has substantial experience in facilitating cross-border activities for a diverse mix of companies, as well as entrepreneurs, ultra-high-net-worth individuals, and family offices. While the firm is organised into four core departments: Corporate, Real Estate, Dispute Resolution and Funds, Finance and Regulatory, our expertise spans a broad spectrum of areas and industries, allowing us to provide coordinated advice on complex issues to support our clients throughout their business cycles and personal journeys. This guide is for general guidance only. Specific legal advice should be obtained in all cases. Fladgate LLP is regulated by the Solicitors Regulation Authority, number 484783. ©Fladgate 2023. This material is the copyright of Fladgate LLP and is not to be reproduced in whole or in part without prior written consent.

ILN Corporate Group – Establishing a Business Entity Series

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