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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: United States of America: associated persons

Article 9(1) provides that each country may apply its own domestic law regarding transactions between associated persons (ICTA88/S28AA in the case of the United Kingdom, see INTM153100). Where the profits of an enterprise are consequently increased for United States tax purposes, the United Kingdom may be asked to make an appropriate adjustment to the tax charged on the profits of the associated enterprise in the United Kingdom (Article 9(2)). Any claim by a United Kingdom enterprise for a corresponding adjustment should be referred to RP International , Business Tax Group with the file (INTM161320 ).