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Transfer pricing decision published
A decision on a tax dispute between HMRC and DSG International has been published by specialist tax tribunal the Special Commissioners. The case concerned transfer pricing and the treatment of profits made by an Isle of Man subsidiary which reinsured Extended Warranties sold by the Group. This is the first transfer pricing case that the Special Commissioners have heard and the decision represents a significant victory for HMRC. The Commissioner's decision also supported the economic analysis put forward by HMRC's experts and their interpretation of the OECD transfer pricing guidelines.
Frontier (Europe) Director Simon Gaysford was instructed by HMRC as an economic expert.
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