Latest news with #transferPricing
Yahoo
26-05-2025
- Business
- Yahoo
Grant Thornton bolsters UK tax practice with new partners
Grant Thornton has strengthened its tax and transfer pricing services in the UK with the appointment of two new partners, Gil Oglesby and Duncan Nott. In the new role, Gil Oglesby will oversee the transformation of the firm's tax function, aiming to optimise tax technology, data, processes, and personnel deployment. Previously, he led Direct Tax & Transformation at ASOS, managing all direct tax compliance and reporting, as well as spearheading tax technology and transformation initiatives. Duncan Nott, with over 25 years of transfer pricing expertise, joins as Transfer Pricing partner. His experience spans various industries and includes advising government bodies on transfer pricing matters. Nott's role at Grant Thornton will involve aiding clients with practical transfer pricing solutions and preparing them for the operational and governance aspects of transfer pricing policy. Additionally, Duncan Nott will collaborate with Grant Thornton's network of Pillar Two specialists to assist clients in navigating the new Global Minimum Tax regulations under the OECD's Pillar Two framework. This tax is designed for large multinationals and represents a significant shift in international tax compliance. Grant Thornton UK Tax head Hazel Platt said: 'It is a pleasure to welcome both Gil and Duncan to the firm. They both bring outstanding experience in their respective areas of expertise that will further enhance our market-leading tax offering. 'They are joining the firm at a crucial time for clients as they face a fast-changing tax outlook, both domestically and cross-border. Ensuring firms have the best processes and protocols in place has never been more important. Having Gil and Duncan on our team means we are even better positioned to help our clients meet those challenges.' Grant Thornton UK, which is part of a global network that employs 76,000 employees across more than 150 countries, is led by over 200 partners and employs over 5,500 professionals. Last week, Grant Thornton appointed Storme Sixeas as the leader of Tax Legislative Affairs in its Washington National Tax Office. Sixeas brings over 20 years of experience in federal tax policy and will provide strategic tax legislative guidance to clients. "Grant Thornton bolsters UK tax practice with new partners" was originally created and published by International Accounting Bulletin, a GlobalData owned brand. The information on this site has been included in good faith for general informational purposes only. It is not intended to amount to advice on which you should rely, and we give no representation, warranty or guarantee, whether express or implied as to its accuracy or completeness. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our site. Sign in to access your portfolio
The National
26-05-2025
- Business
- The National
UAE corporate tax: Can charging different prices for the same product impact liability?
As June approaches, we are four months from the filing deadline faced by the majority of the country's businesses. Of course, it would be far better for everyone concerned if they didn't wait until the final weeks to file returns. Hundreds of thousands of entities trying to submit documents at the same time might cause a strain on the online systems that must be used to complete the process. Having managed many corporate tax returns already, the one element confusing people the most is arm's length trading. While I have written about elements of transfer pricing in the past, the subject is so broad that it could have its separate regular column. Today, I want to address the topic from two fronts. Firstly, explaining what it is and why it matters. Secondly, with so many people and their businesses moving to the UAE, why these types of migration come with their own compliance frameworks. Yes, very often it's plural. An arm's length transaction means the seller would charge the same price to all buyers. This is where the goods or services are of the same value and volume for all purchasers. Delivery can be anywhere in the world. For simplicity, imagine that the seller faces no competition. You either purchase from this entity or go without. That means it is extremely difficult to conceive of a circumstance where there would be different pricing for different people. I hear you say: 'How about if it's a family member or close friend? Am I not allowed to sell my wares for whatever price I like?' Interestingly, you are. Unless it's a legislated government-controlled item and there are few of these. While you can set whatever price you like to whomever you like, for tax purposes, the regulatory authorities want to be assured that you are not setting the price with an objective of gaining a tax advantage. Therefore, in your reporting, you would need to account for any changes in pricing driven by familiarity with one or more customers so that your UAE tax liability is not affected. How is that done? My advice is not to do it in the first place. If reviewed in an audit, this type of activity will raise questions that will remove you from driving your business forward. You might understand how trading with family members is a regulated space, but at what level of relationship does a friend get covered by the same requirements? To avoid doubt, a relation is anyone from great grandfather to great grandchild, and an individual to their second cousin twice removed. That said, what is the equivalent measurement for friends? I have not been able to find anything specific, however, transactions might be challenged if discrepancies in pricing are discovered and it is found that two parties know each other. Where ambiguity like this is found to exist and the amounts are sufficiently material, it would likely be inevitable that the matter might end up in court, with an adjudication being made in adherence to the spirit of the law. On to our second topic. An individual with an existing business in Europe has decided to move to the UAE. The intent is to replicate the operation of the original company. The first emigration is that of the business owner. For tax purposes, you cannot simply leave one country, particularly where you are a national, and move to another. There are rules and processes, coupled with much careful planning that is required to minimise having to satisfy two nations' reporting regimes simultaneously. While the foundational rules for this are reasonably similar in approach by most countries, there can be variability and continuing evolution. For example, when moving to the UAE, how many days of a tax year have you spent in the country you are leaving before you can avoid being a tax resident in that year? A potential second emigration is that of your business. This occurs if you seek to close the existing one and open it in the UAE. That will likely be deemed a sale. Sometimes the old business continues, there might be employees and certain customers who refuse to move, while a carbon copy is set up in the UAE. It's inevitable that some trading among the entities, management and operational staff will be shared and you have to now prove that transactions are being conducted at arm's length plus a connected party operating in two jurisdictions. This can be very messy. Get help.
