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HMRC internal manual

Film Production Company Manual

Avoidance and disclosure: avoidance - transfer pricing

UK transfer pricing rules are set out in TIOPA2010/Part 4.

In applying transfer pricing rules, the UK observes the Transfer Pricing Guidelines issued by the OECD (“Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, Organisation for Economic Co-operation and Development, Paris, 1995”) . Such rules apply to film production as they do to any other sector of the economy.

Paragraph 1.55 of the OECD guidelines addresses the impact of government policies when determining the transfer price of transactions between connected parties. They make clear that such government interventions should be treated as conditions of the market which should be taken into account in evaluating the transfer price. Once this has been done, the question arises whether, in the light of these conditions, the transactions undertaken by the connected parties are consistent with transactions between independent enterprises.