STOTLAND | CONSULTING

Issue No. 04 | October 9, 2026 This week’s review focuses on an Indian Tribunal decision concerning a familiar area of transfer pricing controversy: intra-group management and support services, and the tendency of tax authorities to assign a NIL arm’s-length value to such arrangements. The decision does not break new ground, but it reinforces an important distinction. Establishing that services were actually rendered is one question; determining the arm’s-length considera

The principal development in this week’s Global TP Monitor comes from the United Kingdom, where HM Revenue & Customs has substantially expanded its International Manual to explain the practical application of the UK’s reformed transfer pricing framework and the new Unassessed Transfer Pricing Profits (UTPP) regime. The guidance is especially important for financial transactions. It sharpens the distinction between the pricing benefit created by a guarantee and the borrower’