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HMRC internal manual

International Manual

HM Revenue & Customs
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International Manual: recent changes

Below are details of the amendments that were published on 29 March 2012 (see the update index for all updates):

Page Details of update
INTM343540 DT applications and claims: types of income: dividends: direct investors. Page updated to remove Canada and the US from list of treaties that contain special provisions that allow a direct investor to claim payment of part of the tax credit applying to dividends. The entries for the Netherlands and Switzerland are revised.
INTM453020 Transfer pricing: governance structure and processes: governance process for transfer pricing enquiries: what types of enquiry are within the governance. Additional bullet point inserted to indicate that enquiries relating to companies which have elected into the Tonnage Tax regime are also within the transfer pricing governance structure.
INTM470040 Transfer pricing: addressing double taxation: compensating adjustments: consequential claims following Mutual Agreement Procedure. This is a new page which explains how HMRC will deal with consequential claims arising from a Mutual Agreement Procedure. It explains how we will interpret section 124(4) of TIOPA 2010 and paragraph 49 of Statement of Practice 01/11.
INTM500000 Intra-group funding. We have completely revised and re-structured this section to make it more concise and easier to use. There are now four chapters, rather than the previous nine, which deal with:
  • Transfer pricing the lender
  • Dealing with enquiry function arguments;
  • Group finance companies and the treasury function, and
  • Beneficial ownership (this section is not yet available in full)
Pages INTM505000 to INTM509150 have been withdrawn.