ARTICLE · 19 JANUARY 2010

Transfer Pricing Bulletin - Life After DSG?

CMS Cameron McKenna Nabarro Olswang

Explore more from CMS Cameron McKenna Nabarro Olswang

Over the past few months CMS has increasingly seen tax authorities in the UK, US and across Europe dissecting internal legal agreements and questioning apparently watertight attribution of risks and functions in the pricing models of group transactions.

United KingdomIntellectual Property

Nick Foster-Taylor

Richard Croker

Mark Nichols

Over the past few months CMS has increasingly seen tax authorities in the UK, US and across Europe dissecting internal legal agreements and questioning apparently watertight attribution of risks and functions in the pricing models of group transactions. This quarter's Transfer Pricing Bulletin discusses the ongoing impact of the Special Commissioners' ruling in DSG Retail Ltd v HMRC together with a snapshot of the latest international developments in transfer pricing.

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Life after DSG?

In the wake of the Special Commissioners ruling in DSG Retail Ltd vs HMRC (2009 TC00001) meticulous analysis of inter-company legal and contractual relationships is now more important than ever.

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