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HMRC internal manual

International Manual

International Manual



The International Manual contains up to date guidance for HM Revenue & Customs staff on key international tax issues including practical guidance on working transfer pricing and thin capitalisation cases.

We will continue to expand and update the Manual to include guidance on new legislation and litigation which has become final.


If you have any comments on this Manual, or suggestions for improvement, please send them to:

Neil Nagle

Business Assets & International

Base Protection Policy Team

S1715, Floor 9, Mail Point 3

Central Mail Unit


NE98 1ZZ 

Internal readers should use the feedback button on the intranet left bar.

How to use this Manual

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The left bar is not available to internet users. Instead search the Manuals area using your chosen keywords and look for results in the International Manual (INTM page references).


This manual includes quotations from two OECD publications:

  • the Model Tax Convention on Income and Capital, © OECD 2010, and
  • The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, © OECD 2010

The copyright owner of this material remains OECD.