Practice

Transfer Pricing

In today's environment, transfer pricing needs to be done effectively. It needs proper analysis and clear communication.

Representative experience

Performed and documented a detailed value chain and functional analysis plus profit-split calculations to support a client's negotiations with a tax authority prelitigation.

Advised a UK-based multinational on historic thin capitalization, and modeled impact of new interest deductibility rules.

Designed and implemented a new brand licensing structure for a FTSE-100 company across its operations worldwide.

Advised a global business on supply chain optimisation and the creation of a single hub for IP, procurement and sales related activities.

Conducted a critical review of a tax authority's profit-split model to support MAP negotiations, and helped develop alternative parameters for calculations.

Drafted expert opinions on a number of cases involving allegations of value-shifting through non-arm's length transfer pricing.

Blog Post

Is it time for a review of your transfer pricing arrangements? The potential impact of the HMRC Profit Diversion Compliance Facility

The UK tax authority, HMRC, recently announced the introduction of a new Profit Diversion Compliance Facility, which is aimed at tackling the avoidance of tax by diverting profits outside...

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Hogan Lovells Publications

HMRC introduces Profits Diversion Compliance Facility

HMRC has announced today the introduction of a new Profits Diversion Compliance Facility, which is aimed at tackling the avoidance of tax by multinationals by diverting profits outside the...

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Hogan Lovells Publications

UK Tax Authority tightens the screws on tech companies

When is an amnesty not an amnesty? When the carrot is the (possible) absence of stick.

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International Tax Dispute Resolution & Litigation Summit

Senior Director of Economics & Transfer Pricing, Graham Poole, will be speaking at the International Tax Dispute Resolution & Litigation Summit, on the subject of Diverted Profits...

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Hogan Lovells Publications

Is the UK’s post-Brexit approach to platforms and the digital sector starting to emerge?

The Chancellor of the Exchequer’s statements of intent on a digital service tax and competition law reforms reinforce other recent indications that the UK government is looking...

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