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Nigel M. Dolman

Nigel Dolman works in Baker McKenzie UK's transfer pricing team in London and leads the valuations practice. He joined the Firm in 2009, having previously worked in Ernst & Young’s transfer pricing team for nearly 10 years where he led the team’s intellectual property practice. He has authored numerous publications and articles, focusing primarily on the transfer pricing of intangible assets and intercompany financing.

Since 2015, the UK has adopted the minimum standard of required transfer pricing documentation articulated in BEPS Action 13 (“Guidance on Transfer Pricing Documentation and Country-by-Country Reporting”), namely Country-by-Country-Reporting (CbCR). In its latest consultation paper, HMRC have set out their intention to move away from the BEPS Action 13 minimum standard and to require taxpayers of large multinational enterprise groups (MNE groups) to prepare a master file and local files together with supplemental evidence logs. 

HMRC have also set out a proposal for all UK taxpayers that fall under UK transfer pricing rules to submit an international dealings schedule (IDS) – a highly structured form to capture specific intragroup transactions and activities. If introduced, this would be a significant step change from current documentation requirements and one that will likely increase the compliance burden for many.