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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: SP1/11: secondary adjustments and further information
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
Embedded image changed to link to allow page to publish to GOV.UK

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
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 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
Embedded image changed to link to enable page to publish on GOV.UK
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
Embedded image changed to link to enable page to publish to GOV.UK
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
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 - 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
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 - eligible unrelieved foreign tax - Case B
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 - 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
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: 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 SPT Personal Tax International (Individual Compliance) Bootle
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: SP1/11: secondary adjustments and further information
updated contact for MAP LEAD

published amendments

Transfer Pricing: methodologies: Mutual Agreement Procedure: SP1/11: secondary adjustments and further information
corrected tel number
correcting post code

published amendments

Transfer Pricing: methodologies: Mutual Agreement Procedure: SP1/11: secondary adjustments and further information
Minor formatting change to address. No change to content.

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 CTIAA Business 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