DSG: a turning point in transfer pricing economics
June 17, 2009
Danny Beeton and Hannah Carter of Grant Thornton in the UK explain how the decision in the DSG case is potentially a turning point in transfer pricing economics, at least in the UK
It takes transfer pricing away from the imperfect benchmarking techniques of the arm's-length principle and places it in the context of an alternative framework of bargaining theory. That framework can and probably will be applied by HM Revenue & Customs and other tax authorities in due course. Taxpayers should respond.
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