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HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
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Transfer pricing: legislation: rules: exemptions: special cases

Life assurance companies

Specific guidance concerning the application of certain aspects of TIOPA10/Part 4 to life insurance companies and to connected companies with which they carry out transactions is given in the Life Assurance Manual at paragraph 3.51 onwards.

Petroleum companies

The Large Business Service (“LBS”) is responsible for applying the transfer pricing rules to transactions between companies operating in the North Sea and their associates, who may be resident in the UK. TIOPA10/Part 4 applies to these transactions, except for the disposals of oil and gas to which the rules in ITTOIA05/S225F and CTA10/S281 apply. In both types of case, the application of the rules can have an impact on the computation of profits of associates of North Sea companies. If the application of these rules is considered to be relevant to any Local Compliance enquiry, officers should consult the LBS Oil and Gas sector.

The transfer pricing rules also apply to sales of oil and gas produced overseas by a company in which the buyer and linked companies have an interest of 20 per cent or more. These rules are unlikely to be relevant for cases dealt with outside the LBS. If the application of these rules is considered to be relevant to any Local Compliance enquiry, officers should consult the LBS Oil and Gas sector.