Transfer pricing - OECD update

In order to be awarded CPD units you must answer the following five random questions correctly. If you fail the test, please re-read the article before attempting the questions again.

  1. Which of the following statements is false regarding the OECD guidelines?

  2. What has been introduced by the updated OECD guidelines?

  3. What have the updated OECD guidelines done regarding the hierarchy of methods?

  4. As regards business restructurings, what do the updated OECD guidelines say about a profit/loss potential?

  5. From when do the revised OECD guidelines apply for UK corporation tax purposes?

  6. As regards the attribution of profit to permanent establishments, the treatment of which of the following is not one of the main areas of clarification?

  7. What is HMRC’s position as regards bringing UK domestic law into line with the latest OECD position on profit attribution to UK permanent establishments?

  8. The election for the exemption of profits of overseas permanent establishments will apply to which overseas branches?

  9. What impact is the branch exemption regime likely to have on structures involving overseas branches?

  10. What is the advantage of a branch structure for groups with intra-group debt financing?