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HMRC internal manual

International Manual

Transfer Pricing: Operational guidance: giving transfer pricing advice to customers

Requests for advice on the operation of the transfer pricing rules

This guidance is not intended to cover treaty clearances, which are claims by non-residents to receive royalties or interest at the treaty rate of withholding tax or implementing the EU Interest and Royalties Directive (see INTM400010 onwards).

For any queries or discussions, including a request for advice on the TP treatment of future transactions at the close of an enquiry into previous years, refer to the advice in INTM480540 on real-time working and APAs, and in INTM480550 on Advance Thin Capitalisation Agreements.