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HMRC internal manual

International Manual

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HM Revenue & Customs
Updated
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International Manual: recent changes

Below are details of the amendments that were published on 29 March 2010 (see the update index for all updates)

Section Details of update
   
INTM432040 This section has been updated to include reference to the DSG case.
INTM432055 This is a new page looking at whether there was a transaction or series of transactions in the DSG case.
INTM435090 New page giving details of the DSG case including a summary of the Special Commissioners decision.
INTM463020 The contents of this page have been significantly altered. The page now contains guidance on comparability. Some of the information was originally contained in INTM463030.
INTM463030 The contents of this page have been significantly altered. The page now contains guidance on the Comparable Uncontrolled Price (‘CUP’) method of comparability. Some of the information was originally contained in INTM463020.
INTM463035 This is a new page which contains information about how the Comparable Uncontrolled Price (‘CUP’) method was viewed by the Commissioners in the DSG case.
INTM463065 This is a new page which contains information about how the Profit Split method was viewed by the Commissioners in the DSG case and the approach that was used.
INTM467080 This is a new page which contains guidance about how the concept of bargaining was viewed by the Commissioners in the DSG case and the value of using an expert in this instance.