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HMRC internal manual

International Manual

International Manual: recent changes

Below are details of the amendments that were published on 27 February 2012 (see the update index for all updates).

We’re also taking this opportunity to let you know that on 13 December we updated the international tax pages on the HMRC website. Why not visit our new front page to see the changes we have made?

Page Details of update
INTM162035 UK residents with foreign income or gains: double taxation relief: claims and procedures: apostille. Page corrected so that it refers to the FCO Legalisation Office
INTM267000- INTM267200  Non residents trading in the UK: profits of the permanent establishment. Minor changes in this section where legislation has been rewritten and page references to other manuals have changed.
INTM432112 Transfer pricing: exemptions: small and medium enterprises. Hong Kong is included (with effect from April 2011) on the list of countries which have a double taxation treaty with the UK containing an appropriate non discrimination article
INTM464025 Transfer pricing: types of transactions: transfer of trading stock. Additions to paragraph commencing “In the first type of case outlined …” to clarify treatment of closing stock between connected businesses on cessation of trade
INTM471010 Transfer pricing: real time working of transfer pricing issues and APAs. Changes to contact details for unilateral APAs in the Oil & Gas sector
INTM504010 Inward Investment Support. New page explaining how we can offer assistance and advice to non resident investors who do not currently deal with HMRC
INTM542000 - INTM542250  Thin capitalisation: legislation. We have made several amendments and updates to these pages to provide further clarification about the operation of the thin capitalisation legislation. These changes do not reflect changes in policy or approach.
INTM582000- INTM582140  Thin capitalisation: agreements between HMRC and the group. We have also amended and updated this section to clarify and provide further information on a number of points, including references to the updated Statement of Practice 01/12 which deals with Advance Thin Capitalisation Agreements (ATCAs). Further details of the changes to the thin capitalisation chapters can be obtained from the International Manual editor whose address can be found on page INTM100000.