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HMRC internal manual

International Manual

HM Revenue & Customs
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International Manual: recent changes

This month’s update consists of a major rewrite of our transfer pricing guidance. The old guidance, which used to start at page INTM430000, has been withdrawn and replaced by new pages starting at INTM410000.

We’ve made this change for two reasons. First, we wanted to update the guidance and ensure that it gives a consistent message. And secondly we felt the guidance could be made easier to use. The improvements we have made include reworking the structure so that information is presented in a more logical way, and we’ve increased the use of hyperlinks to make it easier to cross reference other subjects in the manual.

A conversion table from the old page numbering system to the new is available at page INTM489030.

We’d be interested to hear any comments and suggestions about the new guidance. Please send them to Bowen, Mike (CTIAA)

Below are details of the amendments that were published on 26 July 2012 (see the update index for all updates).

Page Details of update
INTM410000 Transfer pricing: introduction: what is transfer pricing? This section is a short introduction to transfer pricing and how the new guidance is structured
INTM412000 - INTM412140  Transfer pricing: legislation: rules. A summary of the UK’s transfer pricing legislation
INTM413000 - INTM413260  Transfer pricing: the main thin capitalisation legislation. We’ve moved the thin cap legislation to sit alongside our summary of transfer pricing rules
INTM421000 - INTM421110  Transfer pricing: methodologies: OECD Guidelines. An overview of the OECD transfer pricing methodologies
INTM422010 - INTM422150  Transfer pricing: Advance Pricing Agreements. This section introduces APAs and includers the text of our Statement of Practice on this subject
INTM423000 - INTM423120  Transfer pricing: Mutual Agreement Procedure. This section introduces MAP and includers the text of our Statement of Practice on this subject
INTM440000 -INTM440260  Transfer pricing: types of transactions. A guide to a number of transaction types which may be encountered.
INTM441000 - INTM441140  Transfer pricing: structures. A guide to a different structures which may be encountered.
INTM480000 - INTM480050  Transfer pricing: operational guidance. A short introductory section setting out the structure of this section and providing guidance on real time working
INTM481000 - INTM481080  Transfer pricing: operational guidance: governance. How the governance procedures work throughout the stages of an enquiry
INTM482000 - INTM482170  Transfer pricing: operational guidance: risk assessment. An overview of transfer pricing risk across a number of areas
INTM483000 - INTM483130  Transfer pricing: operational guidance: workign a transfer pricing case. Advice and guidance about how to conduct a transfer pricing enquiry
INTM484000 - INTM484100  Transfer pricing: operational guidance: examining transfer pricing reports. A suggested approach to reviewing TP reports
INTM485000 - INTM485140  Transfer pricing: operational guidance: evidence gathering. Here we discuss practical issues which case teams may encounter when testing transfer prices, including searches for comparables
INTM486000 - INTM486010  Transfer pricing: operational guidance: interaction with indirect taxes. A short section summarising possible VAT related points which may arise
INTM489000 - INTM489030  Transfer pricing guidance: derivation and destination tables. We’ve provided tables to show the origin of sections in TIOPA 2010 and where the transfer pricing legislation in what was ICTA 1988 can now be found. There is also a conversion table from the old to the new transfer pricing guidance