UK and US companies are members of group. US company is required to bring in a positive transfer-pricing adjustment on a transaction between the two. Question, quite simply, is - can the UK company claim a compensating adjustment? The legislation seems to be quite straightforward, such that the answer is no - because the advantaged person is not subject to UK CT. But is it really as simple as that?
28th Feb 2017
0
Transfer pricing
UK adjustment?