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HMRC internal manual

International Manual

International Manual: recent changes

Below are details of the amendments that were published on 27 April 2015 (see the update index for all updates)

Page  Details of update 
INTM190000 Guidance relating to Controlled Foreign Companies (CFCs) with accounting periods starting on or after 01 January 2013 (in Part 9A, TIOPA 2010) has now been incorporated into the International Manual at INTM190000 onwards. The guidance has been drawn together from draft guidance published over the last two years and has included minor clarifications to detail where these were found to be needed as well as minor changes to Chapters 3, 4 and 9 and further examples of attribution of assets and risks in Chapter 4 and UK capital contributions in Chapter 5.
INTM167000 There are also a few changes to the double taxation relief guidance in INTM167000 onwards relating to non-trading credits on loan relationships and intangible fixed assets to reflect section 49B TIOPA, which was introduced in Finance Act 2014. The pages that have been changed are INTM167140 and INTM167470. Four new pages - INTM167225, INTM167226, INTM167475 and INTM167476, have also been inserted.
INTM595000 Changes to Arbitrage