HMRC internal manual

International Manual

INTM410510 - Transfer pricing: introduction: what is transfer pricing?: Structure of the transfer pricing guidance

An introduction to the transfer pricing guidance

In July 2012, we updated and rewrote the transfer pricing guidance in this manual, creating a structure that is both more intuitive and more logical. These changes mean that references to HMRC’s transfer pricing guidance in other material may direct you to a page which no longer exists. To help readers navigate the new guidance, we summarise below the new sections. Where the new guidance is largely based on pages which have been superseded, we provide the old page numbers as a reference point.

A detailed table of page derivations can be found at INTM489030 to assist with converting page numbers from the previous transfer pricing guidance (where page numbers started with 43, 45, 46 or 47) to the new guidance structure.

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Structure of the guidance

The guidance is divided into five separately numbered sections.


Pages in the 41 series deal with transfer pricing rules, including thin capitalisation, and how they are applied by the key UK legislation at TIOPA10/Part 4 (formerly ICTA88/SCH28AA). We also explain how transfer pricing interacts with other UK legislation. Most of this subject was previously explained in pages at INTM430000 onwards (INTM542000 for thin capitalisation).


We provide a brief overview of OECD approved transfer pricing methodologies at pages starting with 42. This subject was previously covered in pages INTM463000 onwards. We also cover Advance Pricing Agreements and Mutual Agreement Procedure in this section. The MAP material was formerly to be found at INTM470000 onwards. The APA section contains the text of the current APA Statement of Practice which was previously at INTM469000 onwards.

Transactions and structures

Pages starting with 44 address specific transfer pricing issues which may be encountered, including intangibles, share options and particular business structures. Most of this subject was previously explained in INTM464000 and INTM465000 onwards.

Operational guidance

Our final section on pages starting with 48 sets out practical advice and guidance for HMRC officers undertaking transfer pricing enquiries. We also explain the governance procedures which apply to these enquiries. This subject was previously covered in INTM453000, INTM461000 and INTM466000 onwards.

Thin capitalisation guidance

Unlike the previous four sections, the thin capitalisation guidance has not been extensively rewritten, although it has been updated and revised where necessary. It complements the main transfer pricing guidance and is divided into three subsections:

  • Legislation and principles: Pages INTM413000 onwards follow a similar approach to the main transfer pricing legislation pages.
  • Practical guidance: Pages INTM510000 onwards feature extensive guidance about operational issues.
  • Funding: Pages INTM500000 onwards deal with a range of funding issues.