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HMRC internal manual

International Manual

HM Revenue & Customs
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Transfer pricing: Types of transactions: land and buildings

Transactions involving land and buildings

The transfer pricing legislation at TIOPA10/Part 4 applies to transactions involving land and buildings. These sales, when taking place between connected persons, and where assessable as trading income, are subject to the arm’s length principle. Profits that are chargeable as capital gains are not subject to TIOPA10/Part 4; instead the capital gains tax code requires the market value to be substituted for the sale price, where the sale is between connected persons.

Transactions that are subject to TIOPA10/Part 4 also include rent, premiums and services provided under letting agreements.