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HMRC internal manual

International Manual

HM Revenue & Customs
, see all updates

International Manual: recent changes

Below are details of the amendments that were published on 9 August 2011 (see the update index for all updates)

Section Details of update
INTM471000 New page added to transfer pricing guidance entitled ‘Transfer pricing: real time working’
INTM700000 New section added entitled ‘International movements of capital’. This material was previously available on the HMRC internet site in its original draft form. This guidance is now finalised.
INTM346950-INTM346955 Double taxation agreement added for the British Virgin Islands
INTM353030-INTM353040 Double taxation agreement for Hong Kong
INTM359880-INTM359893 Double taxation agreement for Qatar
INTM463090 Cost contribution agreements: extensive rewrite of this page to reflect the current position
INTM169120 Provisions for allowing UK residents foreign tax credit relief for losses: dealing with capital losses. Rewrite of this page.
INTM464140 Transfer pricing rules: application to intra-group provision of employee share plans. Rewrite of this section.
INTM597500-INTM597550 Practical guidance about arbitrage: case identification and working enquiries. Update to this section to reflect structural changes within HMRC.
INTM469000-INTM469075 Advance pricing agreements. New section which contains the text of HMRC Statement of Practice 2/10
INTM468000 Giving transfer pricing advice to taxpayers. Updates to this page to reflect current HMRC real time working strategy
INTM466060 Examining transfer pricing reports: what transactions are covered? Amendments to reflect current HMRC guidance
INTM452000-INTM452050 Transfer pricing governance structure and processes. Minor update to remove references to “stage gate” and replace with current HMRC governance process
INTM451000 Transforming transfer pricing project. Minor update to remove references to “stage gate” and replace with current HMRC governance process
INTM434000-INTM434080 Transfer pricing legislation: enquiries and management provisions. Minor update to remove references to “stage gate” and replace with current HMRC governance process
INTM266040 Non residents trading in the UK: treaty permanent establishment: definition. Correction to wording: “dependent agent”, not “independent agent”
INTM215000-INTM215550 Controlled foreign companies: position before CTSA: Pages deleted as obsolete
INTM333140 Double taxation applications and claims: versions of vouchers. Page deleted.
INTM368530 Double taxation applications and claims: Crown Immunity, Sovereign Immunity and Diplomatic Privilege: Claims and enquiries from Crown or Sovereign Immune claimants. Page deleted