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HMRC internal manual

International Manual

Updates: International Manual

2016

published amendments

International Manual
Manual owner contact details changed

published amendments

Transfer Pricing: Operational guidance: real time working of transfer pricing issues (excluding thin capitalisation)
Updated link to point to Statements of Practice on GOV.UK
Transfer Pricing: methodologies: Mutual Agreement Procedure: HMRC contacts
Updated text to match new link destination on GOV.UK
Updated the link to the Statements of Practice to reflect the latest location on GOV.UK.
Fix line spacing
Updates to Competent Authority names and contact details.
Transfer pricing: operational guidance: governance: what types of enquiry are within the governance?
PRT added to exclusions from TP governance.
Transfer pricing: operational guidance: working a transfer pricing case: penalties
Correction to information on when the term 'negligence' applies (i.e. before April 2009, not after). Also updated Directorate name to CTIS from CTIAA.

published amendments

Controlled Foreign Companies: EEA states - deduction for net economic value against apportionment: Information to be included in applications under ICTA88/S751A
Team name updated
Team Leader updated to Mike Paterson.
Controlled Foreign Companies: How the corporate tax regime works for CFCs: Clearances: Where to send applications
Where to send clearances name changed and email address changed to mailbox

published amendments

Controlled Foreign Companies: The CFC charge gateway chapter 9 - exemptions for profits from qualifying loan relationships: scope of the rules: chapter 9 and double taxation relief
Embedded image changed to link to allow page to publish to GOV.UK
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is Excluded from the definition of a QLR: Section 371IH(9A) to (9E): Examples: Temporary Loan from the UK
Embedded image changed to link to allow page to publish on GOV.UK
Controlled Foreign Companies: The CFC charge gateway chapter 9 - exemptions for profits from qualifying loan relationships: what is a qualifying loan relationship
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published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 6 - Trading Financial Profits: Interaction with Chapter 9
Embedded image changed to link to allow page to publish to GOV.UK
Controlled Foreign Companies: The CFC Charge Gateway Chapter 4 - Profits attributable to UK activities: Case study
Embedded images changed to links to allow page to publish to GOV.UK
Controlled Foreign Companies: The CFC Charge Gateway Chapter 4 - Profits attributable to UK activities: Flowchart
Embedded image changed to link to enable page to publish on GOV.UK
Controlled Foreign Companies: The CFC Charge Gateway Chapter 3 - Determining which (if any) of Chapters 4 to 8 apply: Does Chapter 4 apply?: Conditions A to D: Flowcharts
Embedded images changed to links to allow page to publish on GOV.UK
Controlled Foreign Companies: Introduction to the CFC rules: What Gateway Chapters need to be considered?
Embedded image changed to link to allow page to publish to GOV.UK
Controlled Foreign Companies: Introduction to the CFC rules: Overview
Embedded image changed to link to allow page to publish to GOV.UK

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 3 - Determining which (if any) of Chapters 4 to 8 apply: contents
Correcting typo in short heading
Controlled Foreign Companies: contents
Amending typo

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is Excluded from the definition of a Qualifying Loan Relationship: Section 371IH(7)(8)&(9)
Embedded images changed to links to enable page to publish to GOV.UK
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is Excluded from the definition of a Qualifying Loan Relationship: Section 371IH(5)(6)&(7)
Embedded images changed to links to enable page to publish on GOV.UK
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is Excluded from the definition of a Qualifying Loan Relationship: Section 371IH(3)
Embedded image changed to link to enable page to publish to GOV.UK
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is a Qualifying Loan Relationship: The Ultimate Debtor Rule - Detailed Application: Cash Pooling
Embedded images changed to links to enable page to publish to GOV.UK
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is a Qualifying Loan Relationship: The Ultimate Debtor Rule - Detailed Application: Test by reference to each
Embedded image changed to link to enable page to publish to GOV.UK
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is a Qualifying Loan Relationship: The Ultimate Debtor Rule - Detailed Application: Loans used for more than one purpose
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Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is a Qualifying Loan Relationship: The Ultimate Debtor Rule - Detailed Application: Loans made to acquire an existing loan
Embedded image changed to link to enable page to publish to GOV.UK
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is a Qualifying Loan Relationship: The Ultimate Debtor Rule - Detailed Application: Arrangements involving equity instruments
Embedded image changed to link to enable page to publish on GOV.UK
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is a Qualifying Loan Relationship: The Ultimate Debtor Rule - Detailed Application: Loans made to fund another loan
Embedded image changed to link to enable page to publish on GOV.UK
Controlled Foreign Companies: The CFC charge gateway chapter 9 - exemptions for profits from qualifying loan relationships: what is a qualifying loan relationship: the ultimate debtor rule - overview
Embedded images changed to links to enable page to publish on GOV.UK
INTM210600 - Controlled Foreign Companies: The CFC charge gateway chapter 7 - captive insurance business: exempt foreign permanent establishments
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Controlled Foreign Companies: The CFC charge gateway chapter 7 - captive Insurance Business: contracts of insurance falling within TIOPA10/S371GA(2)
Embedded images changed to links to enable page to publish on GOV.UK

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: What are Qualifying Resources?: Profits from lending to the territory:
Embedded images changed to links to enable page to publish to GOV.UK
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: How do you determine the profits of a Qualifying Loan Relationship: Calculation in the case of a Qualifying Loan
Embedded images changed to links to enable page to publish on GOV.UK
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: How do you determine the profits of a Qualifying Loan Relationship: Calculating profits of Qualifying Loan Relationships
Embedded images changed to links to enable page to publish to GOV.UK
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is Excluded from the definition of a Qualifying Loan Relationship: Section 371IH(10)&(11)
Embedded image changed to link to enable page to publish on GOV.UK

published amendments

Non-residents trading in the UK: domestic law permanent establishment/branch or agency
Embedded image changed to link to allow page to publish to GOV.UK
Controlled Foreign Companies: How the corporate tax regime works for CFCs: CFC supplementary pages (form CT600B reproduced)
Embedded images changed to links to enable page to publish to GOV.UK
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Interaction of Chapter 9 Exemption with the Arbitrage Rules
Embedded image changed to link to enable page to publish to GOV.UK
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: Funds derived from shares:Profits derived from group operations in the relevant territory
Embedded images changed to links to enable page to publish on GOV.UK

published amendments

Arbitrage: practical guidance - examples demonstrating the application of the arbitrage legislation: Example 9 - hybrid entity definition
Embedded image changed to link to enable page to publish to GOV.UK
Arbitrage: practical guidance - examples demonstrating the application of the arbitrage legislation: Example 8 - convertible securities
Embedded image changed to link to enable page to publish to GOV.UK
Arbitrage: practical guidance - examples demonstrating the application of the arbitrage legislation: Example 7 - CFC restructuring
Embedded image changed to link to enable page to publish to GOV.UK
Arbitrage: practical guidance - examples demonstrating the application of the arbitrage legislation: Example 6 - receipts legislation - deferred subscription
Embedded image changed to link to enable page to publish to GOV.UK
Arbitrage: practical guidance - examples demonstrating the application of the arbitrage legislation: Example 2 Part 1 - outward investment
Embedded image changed to link to enable page to publish to GOV.UK
Arbitrage: practical guidance - examples demonstrating the application of the arbitrage legislation: Example 1 Part 1 - inward investment
Embedded image changed to link to enable page to publish to GOV.UK
Arbitrage: legislation and principles - deductions: Deduction not matched by a taxable receipt
Embedded images changed to links to enable page to publish to GOV.UK
Arbitrage: legislation and principles - deductions: Expenses deducted more than once
Embedded image changed to link to enable page to publish to GOV.UK
Transfer pricing: methodologies: Advance Pricing Agreements: Sample agreement
Embedded image changed to link to enable page to publish to GOV.UK
Foreign Permanent Establishments of UK Companies: anti-diversion rule: Diverted Profits Gateway Approach: Example 3.
Embedded image changed to link to enable page to publish to GOV.UK
Foreign Permanent Establishments of UK Companies: anti-diversion rule: Diverted Profits Gateway Approach: Example 2.
Embedded image changed to link to enable page to publish to GOV.UK
Double Taxation Relief: Anti avoidance legislation: Procedure for notices
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UK residents with foreign income or gains: corporation tax: Dividends: subsidiaries entitled to underlying tax relief
Embedded images changed to links to enable page to publish to GOV.UK
UK residents with foreign income or gains: corporation tax: Dividends: control: related companies
Embedded images changed to links to enable page to publish to GOV.UK
UK residents with foreign income or gains: corporation tax: Dividends: extension of relief
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UK residents with foreign income or gains: dividends: Dividends received by UK companies on or after 31 March 2001 - dividends barred from on-shore pools
Embedded image changed to link to enable page to publish to GOV.UK
UK residents with foreign income or gains: dividends: Dividends received by UK companies on or after 31 March 2001 - ADP dividends - example
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UK residents with foreign income or gains: dividends: Dividends received by UK companies on or after 31 March 2001 - eligible unrelieved foreign tax - Case B
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UK residents with foreign income or gains: dividends: Dividends received by UK companies on or after 31 March 2001 - eligible unrelieved foreign tax - Case A
Embedded image changed to link to enable page to publish to GOV.UK
UK residents with foreign income or gains: dividends: Dividends received by UK companies on or after 31 March 2001 - the mixer cap - examples and responsibility
Embedded images changed to links to enable page to publish to GOV.UK
Thin capitalisation: practical guidance: private equity: private equity buyout funding structures
Embedded image changed to link to enable page to publish to GOV.UK
Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: the 20% rule calculation: an example: a transparent collective investment scheme
Embedded image changed to link to enable page to publish to GOV.UK
Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: the 20% rule calculation: an example: an opaque fund
Embedded image changed to link to enable page to publish to GOV.UK

published amendments

Non-residents trading in the UK: Treaty law could potentially affect the UK domestic charge to tax: Treaty law - matching up domestic law with treaty law
Embedded image changed to link to enable page to publish to GOV.UK
Controlled Foreign Companies: Control: Legal and economic control: Legal control
Embedded images changed to link to enable page to publish on GOV.UK
Controlled Foreign Companies: Relevant Interests in a CFC: Other Relevant Interests
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Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: UK company used as a conduit in a CFC shelter: Restriction to Double Taxation Relief by way of credit
Embedded images changed to links to enable page to publish on GOV.UK
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Transfer pricing adjustments in the context of Chapter 9
Embedded images changed to links to enable page to publish to GOV.UK
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Matched Interest Rule: Applying the exemption: Example 2
Embedded images changed to links to enable page to publish to GOV.UK
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Matched Interest Rule: Applying the exemption: Example 1
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Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Matched Interest Rule: Applying the exemption: contents
Embedded images changed to links to enable page to publish to GOV.UK
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: Claims for Qualifying Resources
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Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: What are Qualifying Resources?: Evidence Required: contents
Embedded images changed to links to enable page to publish to GOV.UK
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: What are Qualifying Resources?: Funds derived from shares: Rights Issues
Links updated
Embedded images changed to links to enable page to publish to GOV.UK
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: What are Qualifying Resources?: Funds derived from shares: Share for share exchanges
Embedded images changed to links to enable page publish to GOV.UK

published amendments

Non-residents trading in the UK: domestic law permanent establishment/branch or agency
3rd paragraph: change "They though the could reasonably be described as a branch or as a manager but that the assessment describing him as agent was good" to "They thought he…"

published amendments

International Manual
Manual contact details changed

published amendments

Non-residents trading in the UK: Returns and assessments outside normal time limits: Returns - Corporation Tax
Deleted: 'Effectively that means a delivery deadline of 3 months and 7 days from the date of receipt of the notice by the company (taking account of the additional days allowed by ESC B46).', 4th paragraph at request of content owner.

published amendments

Non-residents trading in the UK: domestic law permanent establishment/branch or agency
Amended the legislation reference from FA03/S148(1)(b) to CTA10/S1141(1)(b). Corrected instances of words running together in paragraphs 1, 3, and 4.
Non-residents trading in the UK: domestic law permanent establishment/branch or agency
Amended the legislation references in the heading and in the body text from FA03/S148 to CTA20/S1141.

published amendments

Foreign entity classification for UK tax purposes: Considerations when using the List of Classifications of Foreign Entities for UK tax purposes
re-write of entire page and change of contact names and addresses
Foreign entity classification for UK tax purposes: Factors to consider in classifying a foreign entity for UK tax purposes
changed of team name in final para
Transfer pricing: legislation: rules: Compensating adjustments
minor amendment to the first bullet - removal of duplicate words
Distribution exemption: Exemption for small companies: qualifying territories
Changed the INTM number in the first para from INTM432112 to INTM412090.

published amendments

Transfer Pricing: Operational guidance: real time working of transfer pricing issues (excluding thin capitalisation)
APA contact details updated.
Transfer pricing: methodologies: Advance Pricing Agreements: expression of interest
Contact details for APAs updated.

published amendments

Transfer Pricing: Types of transactions: Intangibles: Establishing an arm's length price for valuable intangibles: Hard to Value Intangibles
minor formatting
minor formatting
minor formatting
minor formatting
Transfer Pricing: Types of transactions: Services: Low Value-Adding Services
BEPS update to OECD guidance
Transfer pricing: Types of transactions: contents
3 new pages - BEPS updates to OECD guidance
3 new pages - BEPS updates to OECD guidance
BEPS updates to OECD guidelines

published amendments

Transfer pricing: Methodologies: OECD Guidelines: Cost contribution arrangements
minor content changes
content updated re BEPS updates to OECD guidelines
Transfer pricing operational guidance: Accurate delineation of the actual transaction: Risk allocation
minor alterations
Transfer prcing operational guidance: Accurate delineation of the actual transaction: Economically relevant characteristics
Minor amendment to para number
New page - BEPS update to OECD guidelines
Transfer pricing: Types of transactions: intangibles: establishing an arm’s length price for valuable intangibles: product line income statements
content updated re BEPS updates to OECD guidelines
Transfer pricing: Types of transactions: intangibles: branded goods
Contents updated re BEPS updates to OECD guidelines
Transfer pricing operational guidance: Evidence gathering: Establish the facts
contents updated re BEPS updates to OECD guidelines
Transfer Pricing: Transactions and Structures: business structures: research and development
Content updated re BEPS updates to OECD guidelines
Transfer Pricing: Transactions and Structures: business structures: marketing and distribution - other structures
Content updated re BEPS updates to OECD guidelines
Transfer Pricing: Transactions and Structures: business structures: transferring risk
Content updated re BEPS updates to OECD guidelines
Transfer pricing: Types of transactions: setting aside a provision between connected parties
content updated re BEPS updates to OECD guidelines
Transfer pricing: Types of transactions: intangibles: establishing an arm’s length price for valuable intangibles: profit split method
Content updated re BEPS updates to OECD guidelines
Transfer pricing: Types of transactions: intangibles: establishing an arm’s length price for valuable intangibles
content updated re BEPS updates to OECD guidelines
Transfer pricing: Types of transactions: intangibles: fragmentation
content updated re BEPS updates to OECD guidelines
Transfer pricing: Types of transactions: intangibles: how are intangibles exploited?
content updates re BEPS updates to OECD guidelines
Transfer pricing: Types of transactions: intangibles: what are intangibles?
Content updated re BEPS updates to OECD guidelines
Transfer pricing: Types of transactions: centrally provided services
Content updated re BEPS updates to OECD guidelines
Transfer pricing: Types of transactions: Services: arm’s length price
content update re BEPS updates to OECD guidelines
Transfer pricing: Types of transactions: Services: introduction
Contents updated re BEPS updates to OECD guidelines
Transfer pricing: Methodologies: OECD Guidelines: Comparability
Content updated re BEPS updates to OECD guidelines
Transfer pricing: Methodologies: OECD Guidelines: Overview
content updated re BEPS updates to OECD guidelines
Transfer pricing: Methodologies: OECD Guidelines: contents
New page
Transfer pricing: Methodologies: OECD Guidelines: Comparable uncontrolled price: Commodity Transactions
new page - BEPS update on OECD guidelines
Transfer pricing: operational guidance: Evidence gathering: Index page: contents
4 new pages - BEPS updates on OECD guidelines
BEPS updates to OECD guidelines
Transfer pricing operational guidance: Accurate delineation of the actual transaction: Full process
new page - BEPS update to OECD guidelines

published amendments

Transfer pricing: Types of transactions: intangibles: how are intangibles exploited?
minor drafting amendments
Transfer pricing: Types of transactions: intangibles: establishing an arm’s length price for valuable intangibles: profit split method
minor drafting amendments
Transfer pricing: Types of transactions: intangibles: establishing an arm’s length price for valuable intangibles: product line income statements
Minor heading change
Transfer pricing: Types of transactions: intangibles: establishing an arm’s length price for valuable intangibles
minor drafting amendments
Transfer pricing: Types of transactions: Services: introduction
Minor drafting amendments

published amendments

Transfer pricing: Methodologies: OECD Guidelines: Overview
Minor drafting amendment

published amendments

Transfer pricing: Methodologies: OECD Guidelines: Overview
slight change to wording under heading OECD Transfer Pricing Guidelines
Transfer pricing: legislation: rules: introduction
Amendment to remove duplication of text

published amendments

Transfer pricing: legislation: rules: exemptions: SME definition
update to EU website link

published amendments

Non-residents trading in the UK: domestic law permanent establishment/branch or agency
alteration to reference.

2017

published amendments

Transfer Pricing: Operational guidance: giving transfer pricing advice to customers
Republish page to GOV.UK
To republish page to GOV.UK
INTM480530 amendment
amended INTM480530
amendment to INTM480530
EU Interest and Royalties Directive: Overview of the Directive
Republish page to GOV.UK
To republish page to GOV.UK
Transfer Pricing: Operational guidance: real time working of transfer pricing issues (excluding thin capitalisation)
amendment to INTM480540
amendment to INTM480540
Transfer Pricing: Operational guidance: real time working of transfer pricing issues: thin capitalisation
amended INTM480550
AMENDMENTS TO INTM480550

published amendments

Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment managers: the independence test: examples of when satisfied
INTM269080 AMENDMENT
Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment managers: "investment transaction": transactions in units in collective investment schemes
INTM269076 AMENDMENTS
Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents - investment managers: "investment transaction": transactions resulting in a loan relationship or related transaction
INTM269074 AMENDMENT
Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment managers: "investment transaction": transactions in relevant contracts
INTM269072 AMENDMENT
Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment managers: the definition of "investment transaction"
INTM269070 AMENDMENT
Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment manager exemption: the legislation
Amendments to INTM269020 Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment manager exemption: the legislation Overview.

published amendments

Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment managers: "investment transaction": transactions in relevant contracts
INTM269072 amended
Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents - Statement of Practice 1/01 (as revised and reissued November 2016)
INTM269200 amendment
INTM269200 amendment
INTM269200 amendment
Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: Statement of Practice 1/01
INTM269190 amendment
Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: the 20% rule: transparent and opaque funds
INTM269130 amendment
Double Taxation applications and claims: DT forms: Introduction
Updating links to forms

published amendments

Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents - Contents
INTM269079 removed / no longer valid from 19/01/17
INTM269079 WITHDRAWN ON 19/01/17
PAGE WITHDRAWN 19/01/17
PAGE WITHDRAWN 19/01/17
remove INTM269079 on 19/01/2017

published amendments

Transfer pricing: Operational guidance: alternatives to consider before transfer pricing
update to link in the 3rd para

published amendments

Transfer pricing: Operational guidance: alternatives to consider before transfer pricing
no change to text. just needed to publish as it had reverted to draft
x

published amendments

Cash pooling: Legal and commercial arrangements
update link
update new link
Cash pooling: UK company as the cash pool header and the arm’s length principle
updated new links
Cash pooling: setting interest rates for participants on an arm's length basis
link updated
Cash pooling: short term and long term balances held in the cash pool
updated link
Foreign Permanent Establishments of UK Companies: introduction: procedures
new paras added relating to exchange of information
Controlled Foreign Companies: How the corporate tax regime works for CFCs: Clearances: General
New section on Exchange of Information added at the end of the body text
Controlled Foreign Companies: The CFC Charge Gateway Chapter 3 - Determining which (if any) of Chapters 4 to 8 apply: Does Chapter 6 apply?: Group treasury companies
amendment to first heading
Intra-group funding: Cash Pooling: contents
new pages added to INTM
Revised title
Intra-group funding: contents
moved INTM503100
INTM503100 added
Adding a content page
new pages added

published amendments

EU Interest and Royalties Directive: Overview of the Directive
additional section on Exchange of Information added
EU Directive: Interest & Royalties paid between Associated Companies - claims and applications by non- residents
additional section on Exchange of Information added
Double Taxation applications and claims - Introduction: Scope of this guidance
additional section on exchange of information added
Arbitrage: legislation and principles: procedures: Clearance procedures
additional sectoin added on exchang of information.

published amendments

Intra-group funding: Cash Pooling: contents
republish page to reflect in dir gov site
Cash pooling: UK company as long-term borrower in the cash pool
update link SAIM9075
Cash pooling: Introduction to cash pooling
updated live link
Cash pooling: short term and long term balances held in the cash pool
update new links
Cash pooling: setting interest rates for participants on an arm's length basis
update new link
EU Directive: Interest & Royalties paid between Associated Companies - claims and applications by non- residents
exchange of information section added
exchange of information seciton added

published amendments

Cash pooling: UK company as long term depositor in the cash pool
Minor change to formatting of speech marks. No change to text.
Cash pooling: UK company as long-term borrower in the cash pool
Hyperlink to SAIM9075 updated. No change to text
Cash pooling: short term and long term balances held in the cash pool
Hyperlinks updated. No change to text
Cash pooling: setting interest rates for participants on an arm's length basis
Tables reformatted. No chnage to text.

published amendments

UK residents with foreign income or gains: certificates of residence: UK and overseas branches or permanent establishments
Change of wording in the 4th para under the heading “overseas branches or PEs of UK residents”. To help reduce resource to deal with these requests
Change of wording in the 4th para under the heading “overseas branches or Pes of UK residents”. To help reduce resource to deal with these requests
Cash pooling: setting interest rates for participants on an arm's length basis
Minor formatting change to second table. No chnage to text.

published amendments

Transfer pricing: methodologies: Advance Pricing Agreements: types of agreement
update title
INTM422030 UPDATED
Transfer pricing: methodologies: Advance Pricing Agreements: what is an APA?
heading style applied
Change to formatting of list
update page numbering
UPDATE TITLE
INTM422020 updated
Transfer pricing: methodologies: Advance Pricing Agreements: introduction
updated INTM422010
Transfer pricing: methodologies: Advance Pricing Agreements: information to set out in the formal application
updated annex 1
Transfer pricing: methodologies: Advance Pricing Agreements: contents
removed INTM422150
.....
Transfer pricing: methodologies: Advance Pricing Agreements: Sample agreement
to fix numbering
to correct numbering
SP02/10- Advance Pricing Agreements Annex 2 – Sample Agreement update .

published amendments

Transfer pricing operational guidance: Accurate delineation of the actual transaction: Full process
update to diagram link
update to diagram link
Transfer pricing operational guidance: Accurate delineation of the actual transaction: Risk allocation
update diagrame attachment
updating flow chart link

published amendments

Transfer pricing: methodologies: Advance Pricing Agreements: information to set out in the formal application
List formatting changed. No chnage to text

published amendments

Transfer pricing: methodologies: Advance Pricing Agreements: information to set out in the formal application
Formatting updated. No change to text.
Transfer pricing: methodologies: Advance Pricing Agreements: types of agreement
Formatting changed, no change to text.
Transfer pricing: methodologies: Advance Pricing Agreements: what is an APA?
Further chnage to formatting. No chnage to text.
Formatting change to list. No change to text.

published amendments

Controlled Foreign Companies: Management and collection of a CFC charge and reliefs available against a CFC charge: Relief against a sum charged on a chargeable company
new paras added a the start of the page to reflect legislative changes brought in by FA2015
2 new sections added at the beginning to reflect legislative changes brought in by FA2015

published amendments

Controlled Foreign Companies: Management and collection of a CFC charge and reliefs available against a CFC charge: Relief against a sum charged on a chargeable company
Hyperlinks updated. No chnage to text.

published amendments

Controlled Foreign Companies: Management and collection of a CFC charge and reliefs available against a CFC charge: Relief against a sum charged on a chargeable company
Hyperlink updated. No change to text.

published amendments

Transfer pricing: methodologies: Advance Pricing Agreements: Sample agreement
Changed numbering of paragraph to bullets. No text changes.
Changed numbering of paragraph . No text changes.
Changed numbering of paragraph . No text changes.
Transfer pricing: methodologies: Advance Pricing Agreements: revising and renewing
Changed numbering of paragraph to bullets. No text changes.
Transfer pricing: methodologies: Advance Pricing Agreements: revocation and penalties
Changed numbering of paragraph to bullets. No text changes.
Transfer pricing: methodologies: Advance Pricing Agreements: monitoring and review
Changed numbering of paragraph to bullets. No text changes.
Transfer pricing: methodologies: Advance Pricing Agreements: reaching agreement
Changed numbering of paragraph to bullets. No text changes.
Transfer pricing: methodologies: Advance Pricing Agreements: evaluation
Changed numbering of paragraph to bullets. No text changes.
Transfer pricing: methodologies: Advance Pricing Agreements: formal application
Reordering of numbers on paragraph.
Transfer pricing: methodologies: Advance Pricing Agreements: term of agreement
Numbers reordered
Transfer pricing: methodologies: Advance Pricing Agreements: who may apply?
Numbers reordered
Changed numbering of paragraph to bullets. No text changes.
Changed numbering of paragraph to bullets. No text changes.
Transfer pricing: methodologies: Advance Pricing Agreements: expression of interest
Numbers reordered
Changed numbering of paragraph to bullets. No text changes.
Transfer pricing: methodologies: Advance Pricing Agreements: information to set out in the formal application
List reformatted. No text changes.
Changed paragraph numbering to bullets. No text changes.
Transfer pricing: methodologies: Advance Pricing Agreements: types of agreement
Changed paragraph numbering to bullets. No text changes.
Transfer pricing: methodologies: Advance Pricing Agreements: what is an APA?
Changed numbering of paragraph to bullets. No change to text

published amendments

Non-residents trading in the UK: Treaty law could potentially affect the UK domestic charge to tax: Treaty law - matching up domestic law with treaty law
Link to image updated

published amendments

Transfer pricing: legislation: rules: meaning of “provision” and “transaction”
minor change to INTM412050 'What is meant by ‘provision?’

published amendments

Transfer pricing: legislation: rules: Compensating adjustments
minor change INTM412130
amendments to INTM412130 and INTM483090 WERE MADE
Transfer pricing: operational guidance: working a transfer pricing case: assessments and enquiry closure notices
amendments to INTM483090

published amendments

Non-residents trading in the UK: profits of the PE: Attribution - method of calculation of chargeable profits
INTM2670850 changes made to links no text changes.

published amendments

Foreign entity classification for UK tax purposes: Considerations when using the List of Classifications of Foreign Entities for UK tax purposes
change of contact

published amendments

UK residents with foreign income or gains: corporation tax: Dividends: withholding tax
Hyperlink change
Hyperlink change
UK residents with foreign income or gains: corporation tax: Loan relationships
Hyperlink change
UK residents with foreign income or gains: corporation tax: Loan relationships
Hyperlink change
UK residents with foreign income or gains: corporation tax: Accounting periods ending on or after 3 June 1986 and on or before 5 April 1999; accounting periods beginning on or after 6 April 1999: ACT
Hyperlink change
UK residents with foreign income or gains: corporation tax: Accounting periods ending on or after 3 June 1986 and on or before 5 April 1999; accounting periods beginning on or after 6 April 1999: charges
Hyperlink change
UK residents with foreign income or gains: corporation tax: Accounting periods ending on or after 3 June 1986 and on or before 5 April 1999; accounting periods beginning on or after 6 April 1999
Hyperlink change
UK residents with foreign income or gains: dividends: EC Directive
Hyperlink change
UK residents with foreign income or gains: income arising abroad: Employment - double taxation
Hyperlink change
UK residents with foreign income or gains: income arising abroad: Partnerships
Hyperlink changes
UK residents with foreign income or gains: income arising abroad: Accrued income
Hyperlink change
Exchange of information: General
Hyperlink changes
Company residence: residence under foreign law
Hyperlink change

published amendments

Distribution exemption: Interpretation: certain non-dividend distributions
Hyperlink change
Transfer of assets abroad: Working transfer of assets enquiries with WMBC Edinburgh
Hyperlink change
Transfer of assets abroad: Overview of ITA2007/Sections 721 and 727 (‘Income Charge’)
Hyperlink change
DT applications and claims: Non-resident beneficiaries of UK trusts
Hyperlink change
Non-residents trading in the UK: Treaty law could potentially affect the UK domestic charge to tax: Treaty law - the business profits and permanent establishment Articles 7 & 5
Hyperlink change
Non-residents trading in the UK: Treaty law could potentially affect the UK domestic charge to tax: Treaty law - an introduction
Hyperlink change
UK residents with foreign income or gains: capital gains tax: Remittance basis
Hyperlink change
UK residents with foreign income or gains: corporation tax: Intangible fixed assets
Hyperlink changes

published amendments

Non-residents trading in the UK: profits of the PE: The separate entity principle and use of transfer pricing methodology
Reapplied bookmark links
Non-residents trading in the UK: profits of the PE: Attribution - method of calculation of chargeable profits
Page republished - no change to text
Non-residents trading in the UK: overseas permanent establishments of UK resident companies: approach to capital attribution in the host state
Short title added to page
Non-residents trading in the UK: overseas permanent establishments of UK resident companies: the capital attribution approach
Short title added to page
Non-residents trading in the UK: overseas permanent establishments of UK resident companies: overview
Short title added to page
Double Taxation Agreements: Guernsey: Income from a UK source paid to a resident of Guernsey - Industrial or commercial profits paragraph
Hyperlink & text change
Double Taxation Agreements: Jersey: Income from a UK source paid to a resident of Jersey - Industrial or commercial profits paragraph
Hyperlink & text change
Double Taxation Agreements: Isle of Man: Income from a UK source paid to a resident of the Isle of Man - Industrial or commercial profits paragraph
Minor text change
Hyperlink & text change

published amendments

International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes

published amendments

International Manual: update index
Menu updated
International manual: changes 21 October 2014
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
INTM Manual: changes 30 June 2014
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: changes 29 November 2012
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes
International Manual: recent changes
Minor formatting changes

published amendments

Double taxation: concept and principles: UK enabling legislation - relief under double taxation agreements
Hyperlink change
Company residence: 'Treaty non-resident' companies
Hyperlink changes

published amendments

Transfer Pricing: methodologies: Mutual Agreement Procedure: HMRC contacts
updated contact for MAP LEAD

published amendments

Transfer Pricing: methodologies: Mutual Agreement Procedure: HMRC contacts
corrected tel number
correcting post code

published amendments

Intra-group funding: group finance companies and the treasury function: Centralising the finance function: tax considerations
updated short title
Intra-group funding: group finance companies and the treasury function: Risk assessment
Updated short title
Intra-group funding: group finance companies and the treasury function: Centralising the finance function - commercial considerations
updated short title
Intra-group funding: group finance companies and the treasury function: Thin capitalisation risk assessment
Updated short title
Intra-group funding: group finance companies and the treasury function: Types of company
updated short title
Intra-group funding: group finance companies and the treasury function: Functional analysis
Updated short title
Intra-group funding: group finance companies and the treasury function: Applying a transfer pricing method
Updated short title
Intra-group funding: group finance companies and the treasury function: Introduction
updated short title
Interest imputation: dealing with ‘equity function’ arguments: referrals to Business, Assets & International
updated short title
Interest imputation: dealing with ‘equity function’ arguments: Issues affecting equity function cases
updated short title
Interest imputation: dealing with ‘equity function’ arguments: Preparatory work
updated short title
Interest imputation: dealing with ‘equity function’ arguments: Working a case
updated short title
Interest imputation: dealing with ‘equity function’ arguments: HMRC response
updated short title
Interest imputation: dealing with ‘equity function’ arguments: Introduction
updated short title
Interest imputation: transfer pricing the lender: tax implications of outward lending
Upper case in short title
Short title update
Interest imputation: transfer pricing the lender: treatment of exchange differences
updated short title
Interest imputation: transfer pricing the lender: implicit and explicit loan guarantees
updated short title
Interest imputation: transfer pricing the lender: working a case
updated short title
Interest imputation: transfer pricing the lender: information gathering on outward loan cases
updated short title
Interest imputation: transfer pricing the lender: detecting and evaluating loans to connected parties
updated short title

published amendments

Foreign entity classification for UK tax purposes: List of Classifications of Foreign Entities for UK tax purposes
Table modified

published amendments

Non-residents trading in the UK: contents
content pages amended
Non-residents trading in the UK: permanent establishment: domestic and treaty law: Contents
Page title changed as part of update to manual
Non-residents trading in the UK: permanent establishment: domestic and treaty law: Introduction
Page content replaced as part of revamp of International manual.

published amendments

Non-residents trading in the UK: Introduction: Introduction to the module
inserted link
Non-residents trading in the UK: contents
New page added - INTM269510
Non-residents trading in the UK: introduction: contents
Updated page titles to include contents
Non-residents trading in the UK: Is there a charge under domestic legislation: Contents
Menu page entries changed to reflect new content in this section

published amendments

Non-residents trading in the UK: permanent establishment: domestic and treaty law: permanent establishment definition
formatting
Non-residents trading in the UK: Is there a charge under domestic legislation: Domestic charging provisions
format
Non-residents trading in the UK: Is there a charge under domestic legislation: Trading in the UK: Making a contract
heading style
line spacing
Non-residents trading in the UK: Is there a charge under domestic legislation: Trading in the UK: Whether trading
heading style
Non-residents trading in the UK: Is there a charge under domestic legislation: Trading in the UK: Introduction
none
none
Non-residents trading in the UK: Introduction: Relevant legislation
...
Non-residents trading in the UK: Introduction: Introduction to the module
]
Non-residents trading in the UK: PE definition - derivation and destination table
Line beginning “265030” – remove additional “/” at end of last column

published amendments

Non-residents trading in the UK: contents
Added INTM267000, INTM268000, INTM269000 and INTM269500 back to menu
Non-residents trading in the UK: permanent establishment: domestic and treaty law: Industry focus 1: e-commerce
formatting
formatting
Non-residents trading in the UK: permanent establishment: domestic and treaty law: Industry focus 2: building site or construction or installation project
formatting
formatting
formatting
Non-residents trading in the UK: permanent establishment: domestic and treaty law: dependent agent permanent establishment (‘DAPE’): agent of independent status
formatting
formatting
Non-residents trading in the UK: permanent establishment: domestic and treaty law: dependent agent permanent establishment (‘DAPE’): common law v civil law
formatting
formatting
Non-residents trading in the UK: permanent establishment: domestic and treaty law: Dependent agent permanent establishment (‘DAPE’):
formatting
formatting
Non-residents trading in the UK: permanent establishment: domestic and treaty law: taxation of services
formatting
Non-residents trading in the UK: permanent establishment: domestic and treaty law: dependent agent permanent establishment (‘DAPE’): agent acting on behalf of a non-resident enterprise
formatting
Non-residents trading in the UK: permanent establishment: domestic and treaty law: permanent establishment definition: BEPS update to Article 5 of the OECD Model Tax Convention in Income and on Capital (‘MTC’)
formatting
Non-residents trading in the UK: permanent establishment: domestic and treaty law: permanent establishment definition
formatting

published amendments

Non-residents trading in the UK: Introduction: Introduction to the module
Updated bookmark links
Non-residents trading in the UK: permanent establishment: domestic and treaty law: permanent establishment definition
format

published amendments

Non-residents trading in the UK: permanent establishment: domestic and treaty law: permanent establishment definition
List format changed. No changhe to text.

published amendments

DT claims and applications - Types of income: Pensions and Annuities
The table is not correctly formatted on the Gov.UK site and this requires changing as per the table in the body text on the Intranet page.

published amendments

DT claims and applications - Types of income: Pensions and Annuities
The table was formatted incorerectly

published amendments

DT claims and applications - Types of income: Pensions and Annuities
Formatting on table is not correct

published amendments

DT claims and applications - Types of income: Pensions and Annuities
Change in table

published amendments

Foreign entity classification for UK tax purposes: List of Classifications of Foreign Entities for UK tax purposes
Change to the table

published amendments

Transfer pricing: operational guidance: working a transfer pricing case: assessments and enquiry closure notices
minor changes INTM483090
minor changes to INTM483090
- INTM483090 minor changes to commissioners sanction
minor change to INTM483090 under the heading commissioners sanction

published amendments

UK residents with foreign income or gains: certificates of residence: how a customer should make a request
Address change
Address change

published amendments

Hybrid and other mismatches
title change
minor change
minor change
minor title change
minor title change
title change
minor title change

published amendments

Hybrid and other mismatches
minor change

published amendments

Hybrid and other mismatches
PDF link added to text.

published amendments

Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: Brokers
addition of content What is a broker to INTM269050

2018

published amendments

Immunities and Privileges: Contents
New section for International Manual

published amendments

Immunities and Privileges: Contents
Republish, no chnage to text or menu.

published amendments

Transfer pricing: operational guidance: governance: case teams and the wider transfer pricing community
Change from CRM to CCM
UK residents with foreign income or gains: certificates of residence: what HMRC will check - whether there are any obvious reasons why the customer might not be entitled to treaty benefits
Change from CRM to CCM
Arbitrage: legislation and principles: procedures: Clearance procedures
Change from CRM to CCM
Transfer pricing: methodologies: Advance Pricing Agreements: what is an APA?
Change from CRM to CCM
UK residents with foreign income or gains: certificates of residence: how a customer should make a request
Change from CRM to CCM
Thin capitalisation: practical guidance: the Advance Thin Capitalisation Agreement process: completing the process
Change from CRM to CCM
Foreign Permanent Establishments of UK Companies: introduction: election for S18A to take effect
Change from CRM to CCM
How the corporate tax works for Controlled Foreign Companies: When to make a return in respect of a Controlled Foreign Company
Change from CRM to CCM
Transfer pricing: risk assessment: issues to consider before starting a transfer pricing enquiry: resources
Change from CRM to CCM
Transfer pricing: operational guidance: governance: the resolution stage
Change CRM to CCM
Transfer pricing: methodologies: Advance Pricing Agreements: formal application
Change from CRM to CCM
Controlled Foreign Companies: How the corporate tax regime works for CFCs: When to make a return in respect of a CFC
Change from CRM to CCM
Transfer pricing: operational guidance: governance: the selection stage
Change CRM to CCM
Arbitrage: practical guidance: case identification and working of enquiries: The arbitrage team in Business, Assets & International
Change from CRM to CCM
Foreign banks trading in the UK through permanent establishments: The approach in determining an adjustment to funding costs - STEP 2: Risk weighting the assets - the Basel II regulatory regime: Reporting
Change from CRM to CCM
International movements of capital: Reporting requirement: where should reports be sent?
Change CRM to CCM
Changing CRM to CCM

published amendments

International Manual: recent changes
Change from CRM to CCM
Transfer pricing: operational guidance: governance: case teams and the wider transfer pricing community
Change CRM to CCM
Controlled Foreign Companies: The CFC Charge Gateway Chapter 6 - Trading Finance Profits: Factors relevant to the capitalisation of insurance companies
Change from CRM to CCM
Controlled Foreign Companies: The CFC Charge Gateway Chapter 6 - Trading Finance Profits: Capital requirements in the banking sector.
Change from CRM to CCM
Controlled Foreign Companies: How the corporate tax regime works for CFCs: Clearances: General
Change from CRM to CCM
International movements of capital: Exclusions: cash pooling arrangements
Change from CRM to CCM
Thin capitalisation: practical guidance: the Advance Thin Capitalisation Agreement process: when can an ATCA application be made, and what periods can it apply to?
Change CRM to CCM
Cash pooling: risk assessment/compliance checks
Change from CRM to CCM
Thin capitalisation: practical guidance: the Advance Thin Capitalisation Agreement process: renewing the ATCA
Change from CRM to CCM
Transfer pricing: methodologies: Advance Pricing Agreements: expression of interest
Change from CRM to CCM
Cash pooling: UK company as long-term borrower in the cash pool
Change from CRM to CCM
Controlled Foreign Companies: How the corporate tax regime works for CFCs: Clearances: Where to send applications
Change from CRM to CCM
Transfer pricing: methodologies: Advance Pricing Agreements: monitoring and review
Change from CRM to CCM
Thin capitalisation: practical guidance: creating agreements between HMRC and the group: statement of practice 01/12
Change CRM to CCM
UK residents with foreign income or gains: certificates of residence: information to be supplied with a request
Change CRM to CCM
The Non-resident Landlords Scheme: How non-resident landlords can apply to get their UK rent paid gross
Hyperlink added
Double Taxation applications and claims: applicants/claimants: International associations: What the difference is between an international association and an international organisation
Hyperlink update

published amendments

Double Taxation applications and claims: refusal of relief: What to do if relief is not available - applications for relief at source under Double Taxation treaties
Change from CTIAA to CSTD
UK residents with foreign income or gains: income arising abroad: Branch profits - arm's length principle
Change from CTIAA to CSTD
Double Taxation applications and claims: Repayment claims from non-residents: Enquiries: Planning an enquiry
Change from CTIAA to CSTD
Investment from abroad: Inward Investment Support
Change from CTIAA to CSTD
Double taxation agreements: residence: Status of diplomats etc
Change from CTIAA to CSTD
Interest imputation: dealing with ‘equity function’ arguments: referrals to Business, Assets & International
Change from CTIAA to BAI
Arbitrage: practical guidance: case identification and working of enquiries: The arbitrage team in Business, Assets & International
Change from CTIAA to BAI
Company residence: when to make a submission to BAI
Minor title change
Change from CTIAA to BAI

published amendments

Company residence: non-standard treaty tie-breakers
change from CTIAA to CSTD
Foreign tax paid on trade income: limitation on credit: 1998 legislation - 'Just and reasonable' financing cost
change from CTIAA to CSTD
UK residents with foreign income or gains: income arising abroad: Definition of government remuneration
change from CTIAA to CSTD
Exchange of information: Use and Disclosure of information received from overseas
change from CTIAA to CSTD
Interest imputation: dealing with ‘equity function’ arguments: Issues affecting equity function cases
change from CTIAA to CSTD
Transfer pricing: operational guidance: working a transfer pricing case: assessments and enquiry closure notices
change from CTIAA to CSTD
Transfer pricing: legislation: rules: exemptions: small and medium sized enterprises
change from CTIAA to CSTD
UK residents with foreign income or gains: income arising abroad: Partnerships
change from CITAA to CSTD
UK residents with foreign income or gains: income arising abroad: Dividends
change from CTIAA to CSTD
Transfer pricing: operational guidance: governance: the Transfer Pricing Group
Change from CTIAA to CSTD
Transfer pricing: the main thin capitalisation legislation: Borrowing capacity - the borrowing unit
change from CTIAA to CSTD
EU Interest and Royalties Directive: Anti-avoidance measures
change from CTIAA to CSTD
UK residents with foreign income or gains: corporation tax: Dividends: voting power reduced after 1st April 1972: extension of unilateral relief
change from CTIAA to CSTD
UK residents with foreign income or gains: dividends: Underlying tax
Change from CTIAA to CSTD
Double Taxation applications and claims: Repayment claims from non-residents: Enquiries: Key points about opening an enquiry
change from CTIAA to CSTD
Arbitrage: practical guidance: case identification and working of enquiries: Running enquiries into the self assessment of a company to which the arbitrage legislation applies
change from CTIAA to CSTD
Exchange of information: Spontaneous exchanges
change from CTIAA to CSTD
Double Taxation applications and claims: Repayment claims from non-residents: closing an enquiry: Key points about closing an enquiry
change from CTIAA to CSTD
Double Taxation applications and claims: Repayment claims from non-residents: Enquiries: What to do before you open an enquiry
change from CTIAA to CSTD
Transfer pricing: Types of transactions: charities
change from CTIAA to CSTD

published amendments

Thin capitalisation: practical guidance: the Advance Thin Capitalisation Agreement process: role of Business, Assets & International
change from CTISA to CSTD
UK residents with foreign income or gains: double taxation relief: Unilateral relief
change from CTIAA to CSTD
UK residents with foreign income or gains: double taxation relief: Foreign tax
change from CTIAA to CSTD
UK residents with foreign income or gains: double taxation relief: Deduction instead of credit
change from CTISA to CSTD
UK residents with foreign income or gains: certificates of residence: customised certificates of residence and side letters
change from CTISA to CSTD
Transfer pricing: methodologies: Advance Pricing Agreements: monitoring and review
change from CTISA to CSTD
UK residents with foreign income or gains: double taxation relief: Lists of qualifying taxes
change from CTISA to CSTD
Transfer pricing: Types of transactions: intangibles: royalties
change from CTIAA to CSTD
Transfer pricing: operational guidance: working a transfer pricing case: penalties: negligence or carelessness
Change from CTIAA to CSTD
Foreign tax paid on trade income: limitation on credit: 1998 legislation - detail
change from CTIAA to CSTD
Transfer Pricing: Transactions and Structures: business structures: marketing and distribution - commissionaires: challenges
change from CTIAA to CSTD
Double taxation agreements: residence: Companies
change from CTIAA to CSTD
Change from CTIAA to CSTD
Double taxation agreements: introduction: OECD and UN model agreements
change from CTIAA to CSTD
Arbitrage: practical guidance: case identification and working of enquiries: profiling for arbitrage cases
change from CTIAA to CSTD
Company residence: 'Treaty non-resident' companies
change from CTIAA to CSTD
Foreign tax paid on trade income: limitations on credit: 2009 legislation
change from CTIAA to CSTD
UK residents with foreign income or gains: income arising abroad: Branch profits
change from CTIAA to CSTD
Thin capitalisation: practical guidance: lending against asset values: lending against tangible assets - land and buildings
slight paragraph amendment
Double taxation agreements: residence: Dual residents
change from CTIAA to CSTD
Intra-group funding: group finance companies and the treasury function: Risk assessment
change from CTIAA to CSTD
Double taxation treaties: Beneficial ownership: Practical consideration of claims
change from CTIAA to CSTD
Transfer pricing: operational guidance: governance: case teams and the wider transfer pricing community
change from CTIAA to CSTD
Transfer pricing: operational guidance: working a transfer pricing case: transfer pricing documentation
Change from CTIAA to CSTD
Transfer Pricing: Transactions and Structures: business structures: valuable intangibles
change from CTIAA to CSTD
UK residents with foreign income or gains: dividends: Dividend articles in double taxation agreements
change from CTIAA to CSTD
Exchange of information: Introduction to EOI and Requests
change from CTIAA to CSTD
Transfer Pricing: Transactions and Structures: business structures: other legislation
Change from CTIAA to CSTD
Foreign Permanent Establishments of UK Companies: introduction: procedures
change from CTIAA to CSTD

published amendments

How the corporate tax regime works for Controlled Foreign Companies: HMRC enquiries: records
change of team name
Controlled Foreign Companies: definitions
change of team name
Controlled Foreign Companies: exemptions - Exempt Activities Test ('EAT'): Wholesale, distributive, financial or service business
change of team name
Controlled Foreign Companies: Reviews: Large groups - arrangements for handling Controlled Foreign Company Returns
change of team name
How the corporate tax regime works for Controlled Foreign Companies: HMRC enquiries: penalties
change team name
Controlled Foreign Companies: definitions
change of team name
How the corporate tax works for Controlled Foreign Companies: When to make a return in respect of a Controlled Foreign Company
change of team name
Controlled Foreign Companies: Reviews: Working individual companies
change of team name
Controlled Foreign Companies: legislation - introduction and outline: Definition of Controlled Foreign Company
change of team name
Company residence: the incorporation rule
change of team name
Controlled Foreign Companies: legislation - introduction and outline: Clearance Procedures
change of team name
How the corporate tax regime works for Controlled Foreign Companies: Clearances: where to send applications
change of team name
Controlled Foreign Companies: legislation - introduction and outline: Guidance on the Controlled Foreign Companies’ rules under self assessment
change of team name
Controlled Foreign Companies: Reviews: Reports to Business, Assets & International, Base Protection Policy Team
change of team name

published amendments

Other terminology: Rate of withholding tax
Updates following termination of the Agreement.
Other terminology: Life insurance - appropriate certification
Updates following termination of the Agreement.
Residence & non-UK domiciles: Effect of certificate
Updates following termination of the Agreement.
Residence & non-UK domiciles: Formally disputed
Updates following termination of the Agreement.
Residence & non-UK domiciles: Requirement to make a return
Updates following termination of the Agreement.
Residence & non-UK domiciles: Residence
Updates following termination of the Agreement.
Examples: Increased one-off payment
Updates following termination of the Agreement.
Examples: Effect of minimum rate & IHT
Updates following termination of the Agreement.
Clearance under the agreement: Certificate
Updates following termination of the Agreement.
Clearance under the agreement: Amounts not cleared: Tax obligations not cleared (the future)
Updates following termination of the Agreement.
Clearance under the agreement: Amounts not cleared: Tax obligations not cleared (the past)
Updates following termination of the Agreement.
Clearance under the agreement: Amounts not cleared: Applicable rates of tax, assessment periods, etc
Updates following termination of the Agreement.
Examples: contents
Updates following termination of the Agreement.
Clearance under the agreement: Amounts not cleared: Overview
Updates following termination of the Agreement.
Clearance under the agreement: Not eligible for clearance
Updates following termination of the Agreement.
Clearance under the agreement: Eligible for clearance
Updates following termination of the Agreement.
Clearance under the agreement: Calculation of one-off charge
Updates following termination of the Agreement.
Clearance under the agreement: Overview
Updates following termination of the Agreement.
Technical guidance for Swiss/UK Tax Cooperation Agreement: Introduction: Swiss agreements with other countries
Updates following termination of the Agreement.
Technical guidance for Swiss/UK Tax Cooperation Agreement: Introduction: UK legislation
Updates following termination of the Agreement.
Technical guidance for Swiss/UK Tax Cooperation Agreement: Introduction: Swiss implementation
Updates following termination of the Agreement.
Technical guidance for Swiss/UK Tax Cooperation Agreement: Introduction: Background
Updates following termination of the Agreement.
UK residents with foreign income or gains: double taxation relief: The source rule - concessions
change from CTISA to CTSD
Transfer pricing: operational guidance: working a transfer pricing case: Exchange of information
change of team name
UK residents with foreign income or gains: certificates of residence: letter of confirmation
change of team name
UK residents with foreign income or gains: certificates of residence: Dual resident companies
change of team name
Non-residents trading in the UK: making of contract
change of team name
Non-residents trading in the UK: place of contract may not be decisive
change of team name
Arbitrage: practical guidance: case identification and working of enquiries: submissions to the arbitrage team in CSTD Business, Assets & International
change of team name

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is a Qualifying Loan Relationship: The Ultimate Debtor Rule - Detailed Application: Loans made to fund another loan
change of team name
Controlled Foreign Companies: How the corporate tax regime works for CFCs: HMRC enquiries: penalties
change of team name
Controlled Foreign Companies: legislation - introduction and outline: Interest and penalties
change of team name
Thin capitalisation: practical guidance: the Advance Thin Capitalisation Agreement process: what types of transactions are within the ATCA regime?
change of team name
Description of double taxation agreements: Taxes covered
change of team name
Description of double taxation agreements: Permanent establishment
change of team name
Transfer pricing: risk assessment: conducting a transfer pricing risk assessment: review of information from other sources
change of team name
Transfer Pricing: Transactions and Structures: business structures: other legislation
change of team name
Transfer Pricing: Transactions and Structures: business structures: research and development
change of team name
Thin capitalisation: practical guidance: creating agreements between HMRC and the group: introduction to the main features of the agreement
change of team name
Description of double taxation agreements: Shipping/air transport
change of team name
Transfer pricing: operational guidance: governance: the selection stage
change of team name
Transfer pricing operational guidance: Evidence gathering: Establish the facts
change of team name
Foreign entity classification for UK tax purposes: Factors to consider in classifying a foreign entity for UK tax purposes
change of team name
Transfer pricing: legislation: rules: exemptions: small and medium sized enterprises
change of team name
Transfer pricing: Types of transactions: setting aside a provision between connected parties
change of team name
Thin capitalisation: practical guidance: measuring debt: adjusting debt calculations: netting off of debt
change of team name
Transfer Pricing: Operational guidance: real time working of transfer pricing issues (excluding thin capitalisation)
change of team name
Thin capitalisation: practical guidance: loan pricing and the use of credit ratings: in-house credit ratings
change of team name
Thin capitalisation: practical guidance: creating agreements between HMRC and the group: covenant conditions
change of team name
Thin capitalisation: practical guidance: the Advance Thin Capitalisation Agreement process: withdrawing from the ATCA process
change of team name
Thin capitalisation: practical guidance: the Advance Thin Capitalisation Agreement process: criteria for acceptance of an ATCA application
change of team name
Thin capitalisation: practical guidance: accountancy issues: introduction: accountancy impact on thin capitalisation
change of team name
Transfer Pricing: Operational guidance: real time working of transfer pricing issues: thin capitalisation
change of team name
The attribution of capital to foreign banking permanent establishments in the UK: Double Taxation Relief problems - Mutual Agreement Procedure
change of team name
Controlled Foreign Companies: legislation - introduction and outline: Board’s notice of approval and rights of appeal
change of team name

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 3 - Determining which (if any) of Chapters 4 to 8 apply: Does Chapter 4 apply?: Conditions A to D: Condition C
Typo correction
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Matched Interest Rule: When does the matched interest rule apply
Typo correction

published amendments

Transfer pricing: operational guidance: working a transfer pricing case: penalties: negligence or carelessness
change team name
Transfer pricing: Types of transactions: intangibles: establishing an arm’s length price for valuable intangibles
change team name
Transfer pricing: the main thin capitalisation legislation: Introduction
change team name
How the corporate tax regime works for Controlled Foreign Companies: HMRC enquiries: Commissioners’ sanction
change team name
Thin capitalisation: practical guidance: loan pricing and the use of credit ratings: extension of the use of credit ratings to thin capitalisation cases
change team name
Transfer Pricing: Transactions and Structures: business structures: valuable intangibles
change team name
Controlled Foreign Companies: EEA states - deduction for net economic value against apportionment: Information to be included in applications under ICTA88/S751A
change of team name
Transfer pricing: Operational guidance: alternatives to consider before transfer pricing
change team name
Controlled Foreign Companies: apportionment of chargeable profits and creditable tax: Interests other than by virtue of ordinary shares alone
change in team name
Controlled Foreign Companies: How the corporate tax regime works for CFCs: HMRC enquiries: records
change team name
Arbitrage: legislation and principles - deductions: interaction with other legislation
change team name
Company residence: the incorporation rule - commencement and transitional provisions
change of team name
Thin capitalisation: practical guidance: the Advance Thin Capitalisation Agreement process: Introduction to the ATCA process and its governance
change of team name
Controlled Foreign Companies: How the corporate tax regime works for CFCs: When to make a return in respect of a CFC
Change of team name
change of team name
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: UK company used as a conduit in a CFC shelter
change of team name
Description of double taxation agreements: Government service
change of team name
Transfer pricing: operational guidance: working a transfer pricing case: penalties
Change of team name
Thin capitalisation: practical guidance: introduction: getting help with thin capitalisation cases
change of team name
Controlled Foreign Companies: Reviews: Other considerations
change of team name
Double taxation relief: foreign tax credit relief for non-residents trading in the UK: UK branches of non-resident banks and overseas life insurance companies - chargeable periods ending on or before 20 March 2000
change of team name
UK residents with foreign income or gains: claims for double taxation relief against UK tax: disputed claims
change in team name
Interest imputation: dealing with ‘equity function’ arguments: referrals to Business, Assets & International
change of team name
UK residents with foreign income or gains: double taxation relief: Referrals and reports to CSTD Business, Assets & International
change of team name
Thin capitalisation: practical guidance: the Advance Thin Capitalisation Agreement process: role of Business, Assets & International
change of team name
Thin capitalisation: practical guidance: introduction: referrals to Business, Assets & International
change of team name

published amendments

Transfer pricing: methodologies: Mutual Agreement Procedure: contents
new content added INTM423130
Transfer Pricing: methodologies: Mutual Agreement Procedure: Introduction to MAP
content updated for SOP 01/2018
change from CTIAA to CSTD
Transfer Pricing: methodologies: Mutual Agreement Procedure: Eligibility for MAP
content updated for SOP 01/2018
change from CTIAA to CSTD
Transfer Pricing: methodologies: Mutual Agreement Procedure: Access to MAP
content updated for SOP 01/2018
Change from CTIAA to CSTD
Transfer Pricing: methodologies: Mutual Agreement Procedure: The MAP process
content updated for SOP 01/2018
Transfer Pricing: methodologies: Mutual Agreement Procedure: The MAP process continued
content updated for SOP 01/2018
change from CTIAA to CSTD
Transfer Pricing: methodologies: Mutual Agreement Procedure: Concluding the MAP
content updated for SOP 01/2018
Transfer Pricing: methodologies: Mutual Agreement Procedure: Methods of giving relief
content updated for SOP 01/2018
Transfer Pricing: methodologies: Mutual Agreement Procedure: Advice on responding to MAP requests
content updated for SOP 01/2018
Transfer Pricing: methodologies: Mutual Agreement Procedure: HMRC contacts
content updated for SOP 01/2018
Minor formatting change to address. No change to content.
Transfer Pricing: methodologies: Mutual Agreement Procedure: Links to other relevant documents
content updated for SOP 01/2018
Transfer Pricing: methodologies: Mutual Agreement Procedure: Other matters
content updated for SOP 01/2018
Transfer pricing: methodologies: Mutual Agreement Procedure: Arbitration
content updated for SOP 01/2018

published amendments

Transfer Pricing: methodologies: Mutual Agreement Procedure: The MAP process
chane abbrv from CA to Competent Authority
Republished to establish links on GOV.UK
Transfer Pricing: methodologies: Mutual Agreement Procedure: Concluding the MAP
change abbreviation of CA to Competent Authority
change from upper case to lower case on title
Republished to establish links on GOV.UK
Transfer Pricing: methodologies: Mutual Agreement Procedure: Access to MAP
change abbreviation of CA to Competent Authority
Republished to establish links on GOV.UK
Transfer Pricing: methodologies: Mutual Agreement Procedures: Information requirements
change from upper case to lower case on title
Transfer Pricing: methodologies: Mutual Agreement Procedure: Links to other relevant documents
change from upper case to lower case on title
Transfer Pricing: methodologies: Mutual Agreement Procedure: HMRC contacts
change from upper case to lower case on title
Email address updated. No chnage to text
Republished to enable links on GOV.UK
Transfer Pricing: methodologies: Mutual Agreement Procedure: Advice on responding to MAP requests
change from upper case to lower case on title
Republished to reset links on GOV.UK
Transfer Pricing: methodologies: Mutual Agreement Procedure: Other matters
change from upper case to lower case on title
Republished to establish links on GOV.UK
Transfer pricing: methodologies: Mutual Agreement Procedure: Arbitration
change from upper case to lower case on title
Republished to establish links on GOV.UK
Transfer Pricing: methodologies: Mutual Agreement Procedure: Methods of giving relief
change from upper case to lower case on title
Republished to establish links on GOV.UK
Transfer Pricing: methodologies: Mutual Agreement Procedure: The MAP process continued
Republished to establish links on GOV.UK
Transfer Pricing: methodologies: Mutual Agreement Procedure: Eligibility for MAP
Page republished to establish links in GOV.UK
Transfer Pricing: methodologies: Mutual Agreement Procedure: Introduction to MAP
Republished to set links on GOV.UK

published amendments

Company residence: 'Treaty non-resident' companies
table removed

published amendments

UK residents with foreign income or gains: certificates of residence: for partnerships
minor para change
paragraphs added

published amendments

Transfer Pricing: methodologies: Mutual Agreement Procedures: Information requirements
correct heading on content
Transfer pricing: methodologies: Mutual Agreement Procedure: Arbitration
change IV to VI
Transfer Pricing: methodologies: Mutual Agreement Procedure: The MAP process
deleted repeated text
Transfer Pricing: methodologies: Mutual Agreement Procedure: Introduction to MAP
change heading

published amendments

Transfer of assets abroad: Working transfer of assets enquiries with WMBC Edinburgh
Update for change of office details
Transfer of assets abroad: what information is needed by WMBC Assets Edinburgh
Update for change of office details
Transfer of assets abroad: checklist of indicators
Update for change of office details
Transfer of assets abroad: Overview of ITA2007/S736 - 742 - exemption from liability
To update for change of office name
Transfer of assets abroad: introduction
To change the contact details to WMBC Assets
Transfer of assets abroad: mandatory referral to WMBC Assets, Edinburgh
To update manual for WMBC Asset involvement

published amendments

Transfer Pricing: Operational guidance: real time working of transfer pricing issues: thin capitalisation
.....
...
...
publishig date amended
update link
updated INTM480550
Transfer Pricing: Operational guidance: real time working of transfer pricing issues (excluding thin capitalisation)
..
updated hyperlink
updated intm480540

published amendments

Transfer Pricing: Operational guidance: real time working of transfer pricing issues: thin capitalisation
to liven up the links

published amendments

Transfer Pricing: methodologies: Mutual Agreement Procedure: HMRC contacts
Address change
Description of double taxation agreements: Mutual agreement procedure
Address change
Foreign tax paid on trade income: limitations on credit: 2009 legislation
Address change
UK residents with foreign income or gains: double taxation relief: Corresponding adjustments and the alternative method
Address change
Foreign Permanent Establishments of UK Companies: anti-diversion rule: Initial gateway filter - Does Chapter 4 apply?
Address change
Arbitrage: practical guidance: case identification and working of enquiries: The arbitrage team in Business, Assets & International
Address change
Arbitrage: legislation and principles: procedures: Clearance procedures
Address change
Controlled Foreign Companies: EEA states - deduction for net economic value against apportionment: Information to be included in applications under ICTA88/S751A
Address change
Foreign entity classification for UK tax purposes: Considerations when using the List of Classifications of Foreign Entities for UK tax purposes
Address change
Investment from abroad: Inward Investment Support
Address change
Address change
Address change
Controlled Foreign Companies: legislation - introduction and outline: Guidance on the Controlled Foreign Companies’ rules under self assessment
Address change
Address change
Controlled Foreign Companies: How the corporate tax regime works for CFCs: Clearances: Where to send applications
Address change
How the corporate tax regime works for Controlled Foreign Companies: Clearances: where to send applications
Address change

published amendments

Exchange of information: Use and Disclosure of information received from overseas
Address change

published amendments

UK residents with foreign income or gains: double taxation relief: Minimum foreign tax
change from CTISA to CSTD
UK residents with foreign income or gains: double taxation relief: Statutory income basis
change from CTISA to CTSD
Controlled Foreign Companies: The CFC Charge Gateway Chapter 6 - Trading Finance Profits: Capital requirements in the banking sector.
change in team name
Transfer pricing: methodologies: Advance Pricing Agreements: Sample agreement
Change of team name
Controlled Foreign Companies: Entity Exemptions: Chapter 14 - The Tax Exemption: The Basic Rule
Change from CTIS to CSTD
Thin capitalisation: practical guidance: lending against asset values: offshore property companies
Change of team name
Controlled Foreign Companies: Apportionment of a CFC’s Chargeable Profits and Creditable Tax: Apportionment on a just and reasonable basis
Change of team name
Foreign entity classification for UK tax purposes: Considerations when using the List of Classifications of Foreign Entities for UK tax purposes
Minor name change
UK residents with foreign income or gains: certificates of residence: UK and overseas branches or permanent establishments
Change in team name
UK residents with foreign income or gains: claims for double taxation relief against UK tax: rate of exchange to use
Change of team name
International Manual
Change in contact name
Controlled Foreign Companies: The CFC Charge Gateway Chapter 3 - Determining which (if any) of Chapters 4 to 8 apply: Does Chapter 4 apply?: HMRC Governance
Change in team name
Non-residents trading in the UK: domestic law permanent establishment/branch or agency
Minor change

published amendments

Transfer Pricing: methodologies: Mutual Agreement Procedure: HMRC contacts
email link
amend email links

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is a Qualifying Loan Relationship: The Ultimate Debtor Rule - Detailed Application: Loans made to fund another loan
Updated link to diagram, no change to text.
Controlled Foreign Companies: The CFC charge gateway chapter 9 - exemptions for profits from qualifying loan relationships: what is a qualifying loan relationship: the ultimate debtor rule - overview
format change
removed links and used text examples

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Matched Interest Rule: Applying the exemption: Example 1
format change
change links to text
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: Claims for Qualifying Resources
change from links to text
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is Excluded from the definition of a Qualifying Loan Relationship: Section 371IH(7)(8)&(9)
format change
change links to text
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is Excluded from the definition of a Qualifying Loan Relationship: Section 371IH(5)(6)&(7)
change from links to text
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is a Qualifying Loan Relationship: The Ultimate Debtor Rule - Detailed Application: Test by reference to each
format change
Change links to text.

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: How do you determine the profits of a Qualifying Loan Relationship: Calculation in the case of a Qualifying Loan
hyperlinks changed to text
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: How do you determine the profits of a Qualifying Loan Relationship: Calculating profits of Qualifying Loan Relationships
Changing hyperlinks to actual text

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Matched Interest Rule: Applying the exemption: Example 2
Format change
Change from hyperlinks to text
change from hyperlinks to text

published amendments

Transfer pricing: Operational guidance: alternatives to consider before transfer pricing
Removed embedded image and replaced with link to PDF to allow pageto publish to GOV.UK
Transfer Pricing: methodologies: Mutual Agreement Procedure: HMRC contacts
updated contacts

published amendments

Controlled Foreign Companies: exemptions - Exempt Activities Test ('EAT'): Further conditions
Links reformatted, no change to text

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 4 - Profits attributable to UK activities: Identification of SPFs
List reformatted. No change to text
List reformatted. No change to text
List reformatted, no change to text.

published amendments

Transfer pricing: operational guidance: governance: what types of enquiry are within the governance?
minor change
minor update

published amendments

Non-residents trading in the UK: Is there a charge under domestic legislation: Trading in the UK: Whether trading
minor update on INTM 262220

published amendments

UK residents with foreign income or gains: certificates of residence: for individuals and companies
paragraph added to reflect a change in policy
UK residents with foreign income or gains: certificates of residence: for partnerships
external links added
UK residents with foreign income or gains: certificates of residence: for trusts
external link added and guidance updated to reflect a policy change

published amendments

UK residents with foreign income or gains: dividends: Underlying tax - minimising foreign tax paid
minor text change
UK residents with foreign income or gains: dividends: Underlying tax
text change
UK residents with foreign income or gains: dividends: Foreign dividends - glossary
text change
UK residents with foreign income or gains: dividends: Underlying tax - dividend resolutions
text change
UK residents with foreign income or gains: dividends: Underlying tax - groups taxed as a single entity overseas
minor text change
UK residents with foreign income or gains: dividends: Tax deducted
text change
UK residents with foreign income or gains: dividends: Underlying tax - computation of relevant profits
text change
UK residents with foreign income or gains: dividends: Dividend stripping
text change
UK residents with foreign income or gains: dividends: Determination of rates of foreign underlying tax - old agreements
text change
UK residents with foreign income or gains: dividends: Unilateral relief - banks
minor text change

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 3 - Determining which (if any) of Chapters 4 to 8 apply: Does Chapter 4 apply?: HMRC Governance
text change
Thin capitalisation: practical guidance: introduction: referrals to Business, Assets & International
minor text change
Controlled Foreign Companies: EEA states - deduction for net economic value against apportionment: Procedures and process
minor text change
UK residents with foreign income or gains: dividends: Dividends received by UK companies on or after 31 March 2001: eligible unrelieved foreign tax - group surrender
text change
DT applications and claims: manufactured payments
text change
Double Taxation applications and claims: Repayment claims from non-residents: The key features
text change
Double Taxation applications and claims - Exchange of information and correspondence with overseas tax authorities: Provisions in Double Taxation Agreements
minor text change
Exchange of information: Introduction to EOI and Requests
address change
Transfer pricing: operational guidance: working a transfer pricing case: transfer pricing documentation
Address change
Transfer pricing: methodologies: Advance Pricing Agreements: expression of interest
Address change

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 3 - Determining which (if any) of Chapters 4 to 8 apply: Does Chapter 4 apply?: contents
link update

published amendments

Foreign Permanent Establishments of UK Companies: introduction: procedures
Address change
Hybrid and other mismatches
format change
format change
format change
Text change
Controlled Foreign Companies: The CFC Charge Gateway Chapter 6 - Trading Finance Profits: Factors relevant to the capitalisation of insurance companies
text change
Controlled Foreign Companies: The CFC Charge Gateway Chapter 6 - Trading Finance Profits: Introduction
text change
UK residents with foreign income or gains: claims for double taxation relief against UK tax: cases where further assessment may be required
minor text change
UK residents with foreign income or gains: claims for double taxation relief against UK tax: extended time limits
minor text change

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 4 - Profits attributable to UK activities: Flowchart
Updated flowchart
Controlled Foreign Companies: The CFC Charge Gateway Chapter 3 - Determining which (if any) of Chapters 4 to 8 apply: Does Chapter 4 apply?: Conditions A to D: Flowcharts
Flowcharts updated
Controlled Foreign Companies: Introduction to the CFC rules: What Gateway Chapters need to be considered?
Updated flowchart
Controlled Foreign Companies: Introduction to the CFC rules: Overview
Updated flowchart

published amendments

UK residents with foreign income or gains: certificates of residence: What HMRC will check - reason and date for which certification is required
text change
format change
Transfer pricing: operational guidance: working a transfer pricing case: transfer pricing documentation
update link
update link
minor update to INTM483030
Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: Capital investment from the UK: Example of capital investment from the UK: Earlier contribution by the UK parent - interest profits
Added Diagram Image links
Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: Capital investment from the UK: Example of capital investment from the UK: Earlier contribution by the UK parent - trading profits
Added Diagram Image Links
Controlled Foreign Companies: The CFC Charge Gateway Chapter 5 - Non-trading finance profits: Capital investment from the UK: Example of capital investment from the UK- back to back investment via a third party
Added Diagram Link

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Matched Interest Rule: When does the revised matched interest rule apply?
Minor change
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Matched Interest Rule: contents
Update index
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is a Qualifying Loan Relationship: The Ultimate Debtor Rule - Detailed Application: Cash Pooling
text change
text change
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is a Qualifying Loan Relationship: The Ultimate Debtor Rule - Detailed Application: Loans used for more than one purpose
text change
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is a Qualifying Loan Relationship: The Ultimate Debtor Rule - Detailed Application: Loans made to acquire an existing loan
text change
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is a Qualifying Loan Relationship: The Ultimate Debtor Rule - Detailed Application: Arrangements involving equity instruments
text change
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is a Qualifying Loan Relationship: The Ultimate Debtor Rule - Detailed Application: Loans made to fund another loan
text change

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Matched Interest Rule: contents
change

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Matched Interest Rule: When does the revised matched interest rule apply?
Revised short title
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Matched Interest Rule: contents
INTM219360 added to menu

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Matched Interest Rule: contents
INTM219370 and INTM219380 added to menu
added new pages to sub-index
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Revised Matched Interest Rule: Applying the exemption: Example 2
Added link to diagram
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Revised Matched Interest Rule: Applying the exemption: Example 1
Added link to diagram
Controlled Foreign Companies: Control: Legal and economic control: Legal control
Diagram updated
Controlled Foreign Companies: Control: Cell companies or similar entities and control
Added sub title
Controlled Foreign Companies: Control: Control determined by accounting standards
Added sub title
Controlled Foreign Companies: Control: Legal and economic control: contents
Added sub title
Controlled Foreign Companies: Control: Introduction
Added sub title
Controlled Foreign Companies: Relevant Interests in a CFC: Other Relevant Interests
Diagram updated
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is Excluded from the definition of a QLR: Section 371IH(9A) to (9E): Examples: Subsequent transfer of UK Loan asset to CFC
Sub title added to page
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is Excluded from the definition of a QLR: Section 371IH(9A) to (9E): Examples: Temporary Loan from the UK
Diagram updated
Controlled Foreign Companies: The CFC charge gateway chapter 9 - exemptions for profits from qualifying loan relationships: what is a qualifying loan relationship
Diagram updated
INTM210600 - Controlled Foreign Companies: The CFC charge gateway chapter 7 - captive insurance business: exempt foreign permanent establishments
Diagram updated
Controlled Foreign Companies: The CFC charge gateway chapter 7 - captive Insurance Business: contracts of insurance falling within TIOPA10/S371GA(2)
Diagrams updated
Controlled Foreign Companies: The CFC Charge Gateway Chapter 6 - Trading Financial Profits: Interaction with Chapter 9
Diagram updated
Controlled Foreign Companies: The CFC Charge Gateway Chapter 4 - Profits attributable to UK activities: Case study
Diagrams updated
Double Taxation applications and claims: applicants/claimants - individuals: Individuals entitled to UK personal allowances
minor text change
various text changes

published amendments

Controlled Foreign Companies: Control: Legal and economic control: Legal control
Page republished
Controlled Foreign Companies: Relevant Interests in a CFC: Other Relevant Interests
Page republished
Controlled Foreign Companies: The CFC charge gateway chapter 9 - exemptions for profits from qualifying loan relationships: what is a qualifying loan relationship
Page republished
INTM210600 - Controlled Foreign Companies: The CFC charge gateway chapter 7 - captive insurance business: exempt foreign permanent establishments
Page republished
Controlled Foreign Companies: The CFC charge gateway chapter 7 - captive Insurance Business: contracts of insurance falling within TIOPA10/S371GA(2)
page republished
Controlled Foreign Companies: The CFC Charge Gateway Chapter 6 - Trading Financial Profits: Interaction with Chapter 9
Page republished
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Revised Matched Interest Rule: Applying the exemption: Example 2
Page republished
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Matched Interest Rule: contents
Page republished
text change
Controlled Foreign Companies: The CFC Charge Gateway Chapter 4 - Profits attributable to UK activities: Case study
Page republished
Page republished
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Matched Interest Rule: Finance Income amounts falling under more than one chapter
text change
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Matched Interest Rule: Amendment to the Worldwide Debt Cap Rules
text change

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: UK company used as a conduit in a CFC shelter: Restriction to Double Taxation Relief by way of deduction to income
Short title added
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: UK company used as a conduit in a CFC shelter: Restriction to Double Taxation Relief by way of credit
Short title added
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is Excluded from the definition of a Qualifying Loan Relationship: Section 371IH(10)&(11)
Updated explanations and diagrams added to page
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is Excluded from the definition of a Qualifying Loan Relationship: Section 371IH(3)
Explanation and link to updated diagram added to page.
Controlled Foreign Companies: The CFC charge gateway chapter 9 - exemptions for profits from qualifying loan relationships: scope of the rules: chapter 9 and double taxation relief
Additional explanation and link to updated diagram.
Controlled Foreign Companies: The CFC Charge Gateway Chapter 6 - Trading Finance Profits: The Basic Rule
Example 1 updated and diagram added

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: What are Qualifying Resources?: Funds derived from shares: Share for share exchanges
Links to diagrams updated
format change
text change
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: What are Qualifying Resources?: Funds derived from shares: Rights Issues
text change
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: Funds derived from shares:Profits derived from group operations in the relevant territory
text change
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: What are Qualifying Resources?: Profits from lending to the territory:
text change

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: What are Qualifying Resources?: Funds derived from shares: Rights Issues
update links
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Matched Interest Rule: Applying the exemption: contents
text change
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: What are Qualifying Resources?: Evidence Required: contents
text change

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: What are Qualifying Resources?: Funds derived from shares: Rights Issues
hyperlink change
hyperlink change
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Transfer pricing adjustments in the context of Chapter 9
text change
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: What are Qualifying Resources?: Funds derived from shares: Share for share exchanges
hyperlink change

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: What are Qualifying Resources?: Funds derived from shares: Rights Issues
Update Broken Link
Update broken link
Update broken link
text change
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Interaction of Chapter 9 Exemption with the Arbitrage Rules
text change
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: UK company used as a conduit in a CFC shelter: Restriction to Double Taxation Relief by way of credit
text change

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is Excluded from the definition of a QLR: Section 371IH(9A) to (9E): Examples: Temporary Loan from the UK
format change

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: Full Exemption - Qualifying Resources: Funds derived from shares:Profits derived from group operations in the relevant territory
Short title added

published amendments

UK residents with foreign income or gains: certificates of residence: how a customer should make a request
text change
text change

published amendments

Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment managers: "investment transaction": transactions in relevant contracts
minor change
text change
Foreign banks trading in the UK through permanent establishments: Transfer of loans
text change
UK residents with foreign income or gains: double taxation relief: ‘Tax spared’ credit
text change
Transfer pricing: operational guidance: working a transfer pricing case: assessments and enquiry closure notices
text change
Non-residents trading in the UK: Is there a charge under domestic legislation: Trading in the UK: Making a contract
Text change
Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment manager exemption: consequences of not meeting conditions
text change
Non-residents trading in the UK: introduction
text change
Non-residents trading in the UK: Treaty law could potentially affect the UK domestic charge to tax: Treaty law - the business profits and permanent establishment Articles 7 & 5
text change
The attribution of capital to foreign banking permanent establishments in the UK: The approach in determining an adjustment to funding costs - STEP 5: Determining the capital attribution tax adjustment:
text change
Description of double taxation agreements: Independent personal services
text change
Description of double taxation agreements: Capital gains
text change
Thin capitalisation: practical guidance: introduction: referrals to Business, Assets & International
Text change
Arbitrage: practical guidance: case identification and working of enquiries: The arbitrage team in Business, Assets & International
Text change
Arbitrage: legislation and principles: procedures: Notices directing that the legislation will apply
text change
Double taxation agreements: introduction: Interpretation of double taxation agreements
text change
UK residents with foreign income or gains: double taxation relief: Lists of qualifying taxes
text change
UK residents with foreign income or gains: claims for double taxation relief against UK tax: disputed claims
text change
UK residents with foreign income or gains: claims for double taxation relief against UK tax: time limits
Minor text change

published amendments

Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is Excluded from the definition of a Qualifying Loan Relationship: Section 371IH(10)&(11)
Link to second image restored
Removed link to second image
Links to images updated
Updated Diagram Link
Page republished
Controlled Foreign Companies: definitions
text change
Company residence: 'Treaty non-resident' companies
text change
Non-residents trading in the UK: place of contract may not be decisive
text change
Controlled Foreign Companies: The CFC Charge Gateway Chapter 9 - Exemptions for profits from Qualifying Loan Relationships: What is a Qualifying Loan Relationship: The Ultimate Debtor Rule - Detailed Application: Cash Pooling
Updated Diagram
EU Interest and Royalties Directive: What the Directive says
text change
UK residents with foreign income or gains: corporation tax: Loan relationships: mark to market [APs ending before 1 January 2005]
text change
Double taxation treaties: Beneficial ownership: Importance of beneficial ownership
text change
Thin capitalisation: practical guidance: accountancy issues: the change in the treatment of preference shares under IFRS
text change
UK residents with foreign income or gains: income arising abroad: Definition of government remuneration
text change

published amendments

UK residents with foreign income or gains: certificates of residence: for UK registered pension schemes: overview
FORMAT CHANGE

published amendments

Double Taxation Relief: UK residents with foreign income or gains: certificates of residence: contents
order change
Change to contents page
contents page added