Allocation issues: Transfer pricing and tax avoidance: just and reasonable solutions?

Article by Jonathan Schwarz (first published on KluwerTaxBlog)

When the UK introduced its diverted profits tax, I was telephoned by a lawyer at the US Treasury. He wanted to know whether the “just and reasonable” apportionment of profits, in certain circumstances where DPT applied, was a new development? What did it mean?

I was reminded of that discussion this week as a result of two very recent judgements in the UK where the just and reasonable apportionment principle was engaged.

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