Solutions

Transfer Pricing Controversy

What are Transfer Pricing disputes and how can they be resolved or prevented?

Transfer pricing controversy lifecycle

What is transfer pricing controversy?

What is transfer pricing controversy? Eddie Morris, Tax Partner, discusses transfer pricing controversy and how it isn’t as controversial as you might think.

Using Advance Pricing Agreements (APAs) to avoid transfer pricing disputes

What is an Advance Pricing Agreement (APA)? And how can they be used to prevent transfer pricing disputes?

Using Mutual Agreement Procedures (MAPs) to resolve double taxation

How can Mutual Agreement Procedures (MAPs) be used to resolve double taxation? Rochelle Baptiste, Tax Consultant, discusses this in our latest Transfer Pricing Controversy video.

Profit Diversion Compliance Facility

The Profit Diversion Compliance Facility (PDCF) was launched by HMRC in early 2019. In a PDCF, the business effectively conducts their own investigation into transfer pricing disputes.

The International Compliance Assurance Programme

Want to know more about the International Compliance Assurance Programme (ICAP), and simultaneous and joint audits?

Contacts

Eddie Morris

Eddie Morris

Partner

Eddie served for 12 years at HMRC’s International Head Office on transfer pricing controversy cases before joining Deloitte. As well as interacting with HMRC at a policy level, he helps clients with c... More

Jen Breeze

Jen Breeze

Partner

Jennifer is a Partner in Deloitte’s transfer pricing team based in London, with over fifteen years of experience specialising in transfer pricing. Jennifer advises clients across the full spectrum of ... More

Andrew Skipsey

Andrew Skipsey

Director

  Andrew is a Director in the FTSE Transfer Pricing team based in London. He advises clients on appropriate transfer pricing policies, supporting documentation and dealing with tax administration chal... More

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Jamie Bedford

Jamie Bedford

Director

Jamie is a Director in the Foreign Owned Transfer Pricing team based in London. He specialises in Transfer Pricing and International Tax disputes and he leads Deloitte’s response to HMRC’s Profit Dive... More

Iain Whittle

Iain Whittle

Director

Iain is a transfer pricing director in the UK focusing on tax controversy and in particular, HMRC audits, advanced pricing agreements (APA) and mutual agreement procedure (MAP). Iain joined Deloitte i... More