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HMRC internal manual

International Manual

Transfer Pricing: methodologies: Mutual Agreement Procedure: repatriation

Repatriation of funds

During the course of a transfer pricing enquiry it is not uncommon for an enterprise to raise the subject of repatriation of funds. The purpose of such a repatriation is to restore the cash position of the associated enterprises to that which would have existed had arm’s length terms applied to the transactions giving rise to a transfer pricing adjustment; some jurisdictions actually encourage repatriation and have specific rules governing the procedure. It is recommended that any repatriation of funds should only be made following agreement of the transfer pricing reallocation as part of the mutual agreement procedure. Any enquiry on the subject of repatriation, whether this be inbound or outward should be referred to CSTD Business, Assets &  International, Transfer Pricing Team for advice.