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HMRC internal manual

International Manual

Transfer pricing: operational guidance: governance: what types of enquiry are within the governance?

What is covered - and what is not

The transfer pricing governance (see INTM481030) applies from 1 April 2008 to any enquiry or potential enquiry where TIOPA10/Part 4 (formerly ICTA88/SCH28AA) or the arm’s length principle may be invoked, so it covers

  • transfer pricing of goods and services
  • post-return thin capitalisation
  • private equity leveraged buy-outs
  • attribution of profit to permanent establishments (but not the question of whether a permanent establishment exists)
  • Advance Thin Capitalisation Agreements

The transfer pricing governance does not apply to

  • Advance Pricing Agreements
  • Mutual Agreement Procedure/Competent Authority work
  • Petroleum Revenue Tax issues

despite the fact that Transfer Pricing Group (TPG) resource is sometimes used in this work. These areas are subject to their own separate governance.