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Updates: International Manual

2024

7 November 2024 published amendments

Transfer of assets abroad: The income charge: contents

Four new pages added (INTM600825, INTM600830, INTM600835 and INTM600845).

Transfer of assets abroad: History of the legislation: History

New paragraph added at the end of this page, reflecting the changes made by Finance (No 2) Act 2024.

6 November 2024 published amendments

Controlled Foreign Companies: Reviews: Flow chart - what should be included in the corporation tax self assessment return?

Link to drawing never inserted so the page is being archived on advice of the G6 Sandra Dippie.

Controlled Foreign Companies: Reviews: Contents

Page archived.

5 November 2024 published amendments

Transfer of assets abroad: The income charge: The individual - multiple income charges

Four paragraphs added to the end of this page to reflect changes to the ToAA legislation in Finance (No 2) Act 2024 which sought to reverse the effect of the Fisher decision at the Supreme Court, [2023] UKSC 44.

Transfer of assets abroad: The income charge: The individual - the transfer

Quotes from Court of Appeal judgment in Fisher removed. Quotes from Supreme Court decision in Fisher added. References to new ToAA legislation in Finance (No 2) Act 2024 added. This new legislation reversed the Fisher decision.

Transfer of assets abroad: Other general provisions: Just and reasonable basis

Quote from Court of Appeal decision in Fisher removed. New paragraph added, beginning with "In terms of transfers made by closely-held companies...", to reflect legislative changes made by Finance (No 2) Act 2024.

Transfer of assets abroad: Information powers: Restrictions on particulars to be provided by solicitors

Third paragraph (beginning "It also includes...") amended to reflect changes to s749 ITA 2007 made by Finance (No 2) Act 2024

Transfer of assets abroad: Information powers: Restrictions on particulars to be provided by banks

Second bullet point text amended to reflect changes made to s750 ITA07 by Finance (No 2) Act 2024.

Transfer of assets abroad: The Tribunal: The Tribunal's jurisdiction in relation to transfer of assets

New bullet point and text added at the top of the bullet point list on this page, to reflect legislative changes made by Finance (No 2) Act 2024.

31 October 2024 published amendments

Transfer pricing: legislation: rules: the arm's length principle

Updating link at the bottom of the page from INTM480020 to INTM480520.

3 October 2024 published amendments

27 September 2024 published amendments

20 September 2024 published amendments

UK residents with foreign income or gains: income arising abroad: Partnerships

Changed s858 to s852 and repointed DT links to SharePoint rather than Gov.UK.

11 September 2024 published amendments

Transfer pricing: risk assessment: transfer pricing risk indicators: general

new paragraph added including a link the Guidelines for Compliance for Transfer Pricing

Transfer pricing operational guidance: Evidence gathering: Establish the facts

New paragraph added which includes a link to Guidelines for Compliance for Transfer Pricing

3 September 2024 published amendments

14 August 2024 published amendments

6 August 2024 published amendments

International Manual

Changing Ian Provan to Nayem Husain.

2 August 2024 published amendments

26 July 2024 published amendments

24 July 2024 published amendments

19 July 2024 published amendments

Company residence: Statement of Practice 1/90

Minor spelling correction - nusiness to business.

10 July 2024 published amendments

Double Taxation applications and claims: time limit: Notice of intention to claim

Last paragraph updated to reflect MAP request to mailbox.

13 June 2024 published amendments

23 May 2024 published amendments

DT applications and claims - Types of income: Interest

REmoval of outdated wording "HMRC’s position in that case is outlined in Tax Bulletin 9 of November 1993. The instructions at IM3940 also refer". Authorised by Andy Preece G6.

Removal of obsolete wording.

17 May 2024 published amendments

15 May 2024 published amendments

Official Agents

Change requested by policy lead Rufus Rottenberg.

7 May 2024 published amendments

European Union (EU): General Exemption

Page archived

European Union: exemption from Taxation

Updated paragraph to detail terms of exemption

2 May 2024 published amendments

Employees of International Organisations: Experts/consultants

Chnage requested by pag eowner Rufus Rottenberg.

1 May 2024 published amendments

Issues affecting equity function cases

Header update requested by Richard Thopson (BAI)

Intra- group funding - Group finance companies and the treasury function: contents

Header change rqeuested by Ricard Thompson (BAI).

Controlled Foreign Companies: How the corporate tax regime works for CFCs: Clearances: Where to send applications

Updated CFCs Mailbox link to correct address; updated postal address

25 April 2024 published amendments

18 April 2024 published amendments

4 April 2024 published amendments

22 February 2024 published amendments

DT applications and claims - Types of income: Royalties

Page removal as requested by TP Team.

Removal of page per TP Team.

21 February 2024 published amendments

DT applications and claims - Types of income: Royalties

As advised by the Transfer Pricing team, the information on this page is obsolete and should be removed. The link on the page to "Register of Plays" didn't work, so apart from removing the link to this page from "Manual Contents, NFA necessary.

DT applications and claims - Types of income: Royalties

Removing link to 342570.

30 January 2024 published amendments

2023

12 December 2023 published amendments

UK residents with foreign income or gains: double taxation relief: Same income

Paragraphs added to clarify HMRCs approach to determining whether the same income has been taxed in two territories for the purpose of double taxation relief claims.

Foreign entity classification for UK tax purposes: Introduction

Page amended to clarify meaning of "transparent" and "opaque" and give information on purpose of guidance.

Foreign entity classification for UK tax purposes: How HMRC arrives at a general view of foreign entities

Page amended to provide details on how HMRC reach a general view on foreign entities, including factors considered.

Foreign entity classification for UK tax purposes: List of classifications of foreign entities for UK tax purposes

Paragraph added on how list is intended to be used.

Foreign entity classification for UK tax purposes: How HMRC arrives at a definitive view of specific foreign entities

Page added on approach to reaching a definitive view on foreign entity classification

Foreign entity classification for UK tax purposes: HMRC view of Delaware LLCs in light of Anson

Page added on HMRC view of Delaware LLCs in light of Anson

Foreign entity classification for UK tax purposes: Contacts and clearances

Page added for foreign entity classification contact and clearance details

6 December 2023 published amendments

Transfer pricing records: contents

inserting new page/section

9 October 2023 published amendments

Investment from abroad: Inward Investment Support

Page re-published so the the last link displays on the GOV.UK website as well

5 October 2023 published amendments

International Manual

Publish manual to add new page INTM120181.

5 September 2023 published amendments

DT applications and claims - Types of income: Interest

Updated to remove ref to local offices

25 July 2023 published amendments

4 July 2023 published amendments

20 June 2023 published amendments

16 June 2023 published amendments

Non-residents trading in the UK: permanent establishment: domestic and treaty law: fixed place of business: contents

New page added

New page added

new page added and moved to correct location in contents

4 May 2023 published amendments

Transfer pricing: the main thin capitalisation legislation: The interaction between UK taxing rights and double taxation agreements

amending typos and updating the wording in the last section.

amended review date

amendment to date the approach takes effect (very last paragraph on the page)

17 April 2023 published amendments

European Union: exemption of staff

Page updated and last para added

International Manual

INTM owner details updated.

14 April 2023 published amendments

27 March 2023 published amendments

17 March 2023 published amendments

11 February 2023 published amendments

Thin capitalisation: practical guidance: interest cover - debt servicing: discounted debt and convertible debt

re-write

Thin capitalisation: practical guidance: interest cover - debt servicing: factors affecting the interest rate

re-write

updating links

Thin capitalisation: practical guidance: interest cover - debt servicing: LIBOR (London Interbank Offered Rate) replaced by SONIA and Short-Maturity Treasury Debt Issues

re-write

title update

Thin capitalisation: practical guidance: interest cover - debt servicing: what is an acceptable arm's length standard?

wording update

Thin capitalisation: practical guidance: interest cover - debt servicing: cash flow and cash flow covenants

update wording

Thin capitalisation: practical guidance: interest cover - debt servicing: measuring cash flow sufficiency to pay interest and repay capital

re-write

Thin capitalisation: practical guidance: measuring debt: what is an acceptable arm's length standard?

re-write

Thin capitalisation: practical guidance: measuring debt: how the nature of the commercial activity influences the level of debt

re-write

Thin capitalisation: practical guidance: lending against asset values: lending against assets in general

re-write

Thin capitalisation: practical guidance: lending against asset values: lending against tangible assets - assets other than buildings and land

re-write

Thin capitalisation: practical guidance: lending against asset values: lending against tangible assets - land and buildings

re-write

Thin capitalisation: practical guidance: lending against asset values: UK third-party practices - loan to value ratios in property lending

re-write

typo

Thin capitalisation: practical guidance: lending against asset values: UK third party practices - interest rate margins in property lending

re-write

Thin capitalisation: practical guidance: lending against asset values: offshore property companies

re-write

Thin capitalisation: practical guidance: lending against asset values: property companies and the credit crisis

re-write

Thin capitalisation: practical guidance: private equity: what is private equity?

re-write

Thin capitalisation: practical guidance: private equity: private equity buyout funding structures

re-write

Thin capitalisation: practical guidance: private equity: typical debt elements of a private equity buyout

re-write

Thin capitalisation: practical guidance: private equity: payment-in-kind (“PIK”) notes

re-write

Thin capitalisation: practical guidance: creating agreements between HMRC and the group: introduction to the main features of the agreement

re-write

Thin capitalisation: practical guidance: creating agreements between HMRC and the group: maximum amount of debt

wording update

Thin capitalisation: practical guidance: creating agreements between HMRC and the group: interest rate

wording update

Thin capitalisation: practical guidance: third-party loan agreements: the general form of third-party debt agreements

wording update

Thin capitalisation: practical guidance: third-party debt agreements: interest rates and related fees

wording update

Thin capitalisation: practical guidance: the use of credit ratings - contents

Heading change

Thin capitalisation: practical guidance: the use of credit ratings: what is a credit rating?

re-write

Thin capitalisation: practical guidance: the use of credit ratings: how do ratings agencies arrive at their ratings?

wording update

Thin capitalisation: practical guidance: the use of credit ratings: what are credit ratings used for by the market?

re-write

Thin capitalisation: practical guidance: the use of credit ratings: investment grade and non-investment grade credit ratings

title alteration

Thin capitalisation: practical guidance: the use of credit ratings: the distinction between ‘investment grade’ and ‘speculative grade’

re-write

Thin capitalisation: practical guidance: the use of credit ratings: important factors to consider when benchmarking using credit ratings

re-write

Thin capitalisation: practical guidance: the use of credit ratings: in-house credit ratings

re-write

Thin capitalisation: practical guidance: the use of credit ratings: further considerations when using credit ratings in thin capitalisation cases

rewrite

9 January 2023 published amendments

Transfer of assets abroad: contents

Publication of new guidance, replacing what was INTM600010 - INTM600080

7 January 2023 published amendments

Transfer of assets abroad: contents

Addition of new guidance pages

Added link to new guidance pages

2022

20 December 2022 published amendments

Double Taxation applications and claims: time limit: Notice of intention to claim

Team and mailbox updated to ukmap.individuals@hmrc.gov.uk

2 November 2022 published amendments

Immunities and Privileges Overview

Email updated to international.immunitiesprivileges@hmrc.gov.uk

Sovereign Immunity

email changed to BAI, Business International (Immunities & Privileges)

Diplomatic Immunity

email updated to international.immunitiesprivileges@hmrc.gov.uk

Diplomatic Missions: general

email updated to international.immunitiesprivileges@hmrc.gov.uk

Diplomatic Missions: conditions of exemption

email updated to international.immunitiesprivileges@hmrc.gov.uk

Diplomatic Missions: exemptions from Income Tax

Email updated to international.immunitiesprivileges@hmrc.gov.uk

Diplomatic Missions: exemption from Capital Gains Tax

email updated to international.immunitiesprivileges@hmrc.gov.uk

Diplomatic Missions: Communicating with privileged persons

email updated to international.immunitiesprivileges@hmrc.gov.uk

Consuls: Consular Relations Act 1968

email updated to international.immunitiesprivileges@hmrc.gov.uk

6 October 2022 published amendments

21 September 2022 published amendments

20 September 2022 published amendments

12 September 2022 published amendments

25 August 2022 published amendments

19 August 2022 published amendments

3 August 2022 published amendments

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

Removed co-op UA in consultation and agreement with CT Structures Team (V Baker)

20 June 2022 published amendments

15 June 2022 published amendments

Non-residents trading in the UK: Returns and assessments outside normal time limits: Assessing time limits

New paragraph added to guidance in relation assessment and closure notices and Commissioners sanction.

13 June 2022 published amendments

16 May 2022 published amendments

DT claims and applications - Types of income: Pensions and Annuities

NHS pension details updated

NHS pension updated

13 May 2022 published amendments

International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

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International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

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International Manual: recent changes

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International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

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International Manual: recent changes

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International Manual: recent changes

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International Manual: changes 29 November 2012

Page archived – Old legacy update page no longer required

International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

Page archived – Old legacy update page no longer required

International manual: recent changes

Page archived – Old legacy update page no longer required

International Manual: recent changes

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INTM Manual: changes 30 June 2014

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International Manual: recent changes

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International Manual: recent changes

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International manual: changes 21 October 2014

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International Manual: recent changes

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International Manual: update index

Page archived – Old legacy update page no longer required

3 May 2022 published amendments

13 April 2022 published amendments

Hybrids: hybrid payee (Chapter 7): contents

Page INTM555095 added

Hybrids: introduction: legislative changes since 1 January 2017

New guidance added - subheading 'FA 2022'

Hybrids: definition of key terms: 50% investment and 25% investment

First paragraph amended under subheading 'Rules'

Hybrids: hybrid payer (Chapter 5): extent of the mismatch

New final paragraph added under subheading 'Qualifying Institutional Investors'

Hybrids: hybrid payee (Chapter 7): extent of the mismatch - general

New final paragraph added under subheading 'Qualifying Institutional Investors'

Hybrids: hybrid payee (Chapter 7): extent of the mismatch – hybrid payee not chargeable to tax in any territory

Final two paragraphs on the page removed

Hybrid and other mismatches

Guidance amended

2021

11 November 2021 published amendments

2 September 2021 published amendments

The Non-resident Landlords Scheme: Compliance

Changes made to wording under non resident landlords section.

5 August 2021 published amendments

2 July 2021 published amendments

Forces of other countries stationed in UK: residence status

wording added to end of first bulet point 'or their dependents or'

23 June 2021 published amendments

Employees of international organisations: claims by individuals

Email updated to international.immunitiesprivileges@hmrc.gov.uk

Sovereign Immunity

email changed to international.immunitiesprivileges@hmrc.gov.uk

15 June 2021 published amendments

Transfer of assets abroad: introduction

Email address update to Mailbox,Residence,Domicile,DT,RB & ToAA Technical (CS&TD) and team updated to Personal Tax International

Email updated

27 May 2021 published amendments

Interest and Royalty payments - overview

change to wording of para 3.

18 May 2021 published amendments

International Manual

Wording added to comply with GDPR

Wording updated to cover GDPR compliance.

5 May 2021 published amendments

19 April 2021 published amendments

26 March 2021 published amendments

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

Public bodies text changed to;
Customers dealt with by Public Bodies Group, other than charities (see above), should send requests to their CCM or their RES1 reclaim forms to CT Services

links updated

links updated

25 March 2021 published amendments

International organisations: Procedure: how to deal with claims

Email address updated to Immunities & Privileges, International (CS&TD)

25 February 2021 published amendments

Double Taxation applications and claims: Vouchers: Common types of voucher

Hyperlink to table updated

Link to table updated

8 February 2021 published amendments

3 February 2021 published amendments

Transfer of assets abroad: Overview of ITA2007/Sections 721 and 727 (‘Income Charge’)

Reference to SPT Nottingham changed to Trust Compliance, Edinburgh

6 January 2021 published amendments

International Manual

contact details updated

4 January 2021 published amendments

International Manual

amendment to contact details

2020

21 December 2020 published amendments

UK residents with foreign income or gains: dividends: EC Directive

text amended

Interest and Royalty payments - overview

amendment to page as per Adrian Coates instructions

change to title

Interest and Royalty payments - legislation

amendment of text as per Adrian Coates email

Interest and Royalty Payments: Contents

change to title

What the Interest and Royalty Payments legislation says

text amended as per Adrian Coates email

Who is affected by the Interest and Royalty Payments Legislation?

Text amended as per Adrian Coates email

What an interest payment exemption notice covers

Text amended as per Adrian Coates email

Procedures for claims on interest payments

Text amended as per Adrian Coates email

Corporation Tax caseworker communication

Text amended as per Adrian Coates email

Handling enquiries into claims on interest payments

Text amended as per Adrian Coates email

Treatment of royalties under the Interest and Royalty Payments Legislation

Text amended as per Adrian Coates email

What happens if a claim is refused or an exemption notice cancelled

Text amended as per Adrian Coates email

EU Interest and Royalties Directive: Anti-avoidance measures

Text amended as per Adrian Coates email

18 December 2020 published amendments

17 December 2020 published amendments

18 November 2020 published amendments

11 November 2020 published amendments

Description of double taxation agreements: Mutual agreement procedure

Amendment to page providing link to INTM423110

9 November 2020 published amendments

6 November 2020 published amendments

15 October 2020 published amendments

8 October 2020 published amendments

7 October 2020 published amendments

Introduction to Offshore Receipts in respect of Intangible Property (ORIP): Introduction

internal hyperlinks inserted

Introduction to Offshore Receipts in respect of Intangible Property (ORIP): Overview

internal hyperlinks added

Offshore Receipts in respect of Intangible Property (ORIP): Charge to tax on ORIP: Charge to tax on UK-derived amounts

internal hyperlinks added

Offshore Receipts in respect of Intangible Property (ORIP): Exemptions: Limited UK sales

Internal links added

Offshore Receipts in respect of Intangible Property (ORIP): Exemptions: Company resident in specified territory (“listed territory”)

internal hyperlinks added

Offshore Receipts in respect of Intangible Property (ORIP): Exemptions: Business in territory of residence

internal hyperlinks added

Offshore Receipts in respect of Intangible Property (ORIP): Exemptions: Double taxation on amounts within the same control group

internal hyperlinks added

Offshore Receipts in respect of Intangible Property (ORIP): Recovery of tax from related persons: Notice requiring payments

internal links added

Offshore Receipts in respect of Intangible Property (ORIP): Recovery of tax from related persons: Payment Notice: Effects

internal links added

Offshore Receipts in respect of Intangible Property (ORIP): Recovery of tax from related persons: Payment Notice: Appeals

internal hyperlinks added

Offshore Receipts in respect of Intangible Property (ORIP): Recovery of tax from related persons: Payment Notice: Payment

internal hyperlinks added

Offshore Receipts in respect of Intangible Property (ORIP): General: Appeals against assessments

internal hyperlink added

Offshore Receipts in respect of Intangible Property (ORIP): Process and procedures: Overview

internal hyperlinks added

Offshore Receipts in respect of Intangible Property (ORIP): Process and procedures: Treaty claim guidance

internal hyperlinks added

5 October 2020 published amendments

Offshore Receipts in respect of Intangible Property (ORIP): Glossary of terms: Meaning of arising

draft guidance - not yet ready to be published

guidance now live

Offshore Receipts in respect of Intangible Property (ORIP): Glossary of terms: Meaning of residence

draft guidance - not yet ready to be published

guidance now live

Offshore Receipts in respect of Intangible Property (ORIP): Glossary of terms: Meaning of full treaty territory

draft guidance - not yet ready to be published

guidance now live

Offshore Receipts in respect of Intangible Property (ORIP): Glossary of terms: Meaning of “UK-derived amount” and “UK sales”

draft guidance - not yet ready to be published

guidance now live

Offshore Receipts in respect of Intangible Property (ORIP): Glossary of terms: Meaning of intangible property

draft guidance - not yet ready to be published

guidance now live

Offshore Receipts in respect of Intangible Property (ORIP): Glossary of terms: Meaning of Control Groups

draft guidance - not yet ready to be published

guidance now live

Offshore Receipts in respect of Intangible Property (ORIP): Glossary of terms: Meaning of related persons

draft guidance - not yet ready to be published

guidance now live

Offshore Receipts in respect of Intangible Property (ORIP): Glossary of terms: Meaning of 51% and 25% investment

draft guidance - not yet ready to be published

guidance now live

Offshore Receipts in respect of Intangible Property (ORIP): Glossary of terms: Meaning of direct or indirect participation in management, control or capital

draft guidance - not yet ready to be published

guidance now live

Offshore Receipts in respect of Intangible Property (ORIP): Glossary of terms: Other definitions

draft guidance - not yet ready to be published

guidance now live

Introduction to Offshore Receipts in respect of Intangible Property (ORIP): Contents

draft guidance - not yet ready to be published

Introduction to Offshore Receipts in respect of Intangible Property (ORIP): Introduction

draft guidance - not yet ready to be published

Introduction to Offshore Receipts in respect of Intangible Property (ORIP): Overview

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Charge to tax on ORIP: Contents

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Charge to tax on ORIP: Charge to tax on UK-derived amounts

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Charge to tax on ORIP: Apportionment of amounts

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Charge to tax on ORIP: Disregard for third party sales where IP makes an insignificant contribution

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Exemptions: Contents

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Exemptions: Limited UK sales

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Exemptions: Company resident in specified territory (“listed territory”)

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Exemptions: Business in territory of residence

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Exemptions: Foreign tax at least half of UK tax

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Exemptions: Income of opaque partnership in full treaty territory

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Exemptions: Certain bodies corporate that are transparent in a full treaty territory

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Exemptions: Double taxation on amounts within the same control group

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Recovery of tax from related persons: Contents

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Recovery of tax from related persons: Notice requiring payments

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Recovery of tax from related persons: Payment Notice: Contents

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Recovery of tax from related persons: Payment Notice: Effects

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Recovery of tax from related persons: Payment Notice: Appeals

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Recovery of tax from related persons: Payment Notice: Payment

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): General: Contents

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): General: Anti-avoidance

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): General: Interaction with other provisions

now live

Offshore Receipts in respect of Intangible Property (ORIP): General: Appeals against assessments

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Process and procedures: Contents

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Process and procedures: Overview

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Process and procedures: Suggested Notification Template

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Process and procedures: Treaty claims

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Process and procedures: Treaty claim guidance

draft guidance - not yet ready to be published

Offshore Receipts in respect of Intangible Property (ORIP): Glossary of terms: Contents

draft guidance - not yet ready to be published

30 September 2020 published amendments

28 September 2020 published amendments

1 September 2020 published amendments

25 August 2020 published amendments

24 August 2020 published amendments

21 July 2020 published amendments

17 July 2020 published amendments

8 June 2020 published amendments

4 June 2020 published amendments

20 May 2020 published amendments

14 April 2020 published amendments

9 April 2020 published amendments

7 April 2020 published amendments

30 March 2020 published amendments

24 March 2020 published amendments

12 March 2020 published amendments

Exchange of information: Form of report

new template added and paragraph redacted

minor format change

19 February 2020 published amendments

18 February 2020 published amendments

28 January 2020 published amendments

2019

17 December 2019 published amendments

9 December 2019 published amendments

Transfer of assets abroad ('Benefits Charge')

Updated to explain changes under S731 ITA07

9 October 2019 published amendments

Transfer of assets abroad: mandatory referral to WMBC Assets, Edinburgh

links to Trusts Edinburgh amended

links amended

16 September 2019 published amendments

10 September 2019 published amendments

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

hyperlink changed

UK residents with foreign income or gains: income arising abroad: Export credit

HYPERLINKS UPDATED

UK residents with foreign income or gains: dividends: Underlying tax - rate boosting

change to team name

UK residents with foreign income or gains: capital gains tax: Not resident but “ordinarily resident”

hyperlink updated

Non-residents trading in the UK: Is there a charge under domestic legislation: Domestic charging provisions

broken hyperlink fixed

DT Agreements: Japan - Income from a UK source paid to a resident of Japan

page archived

Page archived

Non-residents trading in the UK: overseas permanent establishments of UK resident companies: approach to capital attribution in the host state

hyperlink changed

Double Taxation applications and claims: Repayment claims from non-residents: Enquiries: Planning an enquiry

typo fixed

Double Taxation applications and claims: applicants/claimants - individuals: Guidance on the rules of residence of individuals in the UK

hyprerlink amended

DT applications and claims - Provisional Treaty Relief Scheme for Interest

hyperlink removed

DT Agreements: Austria - Income from a UK source paid to a resident of Austria

Unpublished and archived

DT Agreements: India - Income from a UK source paid to a resident of India

Unpublished and archived

DT Agreements: South Africa - Income from a UK source paid to a resident of South Africa

Unpublished and archived

29 August 2019 published amendments

DT Agreements: Portugal - Income from a UK source paid to a resident of Portugal

page archived

DT Agreements: Portugal - Income from a UK source paid to a resident of Portugal

page archived

DT Agreements: Portugal - Income from a UK source paid to a resident of Portugal

page archived

DT Agreements: Portugal - Income from a UK source paid to a resident of Portugal

page archived

DT Agreements: Portugal - Income from a UK source paid to a resident of Portugal

page archived

DT Agreements: Portugal - Income from a UK source paid to a resident of Portugal

page archived

DT Agreements: Portugal - Income from a UK source paid to a resident of Portugal

page archived

DT Agreements: Qatar - Income from a UK source paid to a resident of Qatar

page archived

DT Agreements: Qatar - Income from a UK source paid to a resident of Qatar

page archived

DT Agreements: Qatar - Income from a UK source paid to a resident of Qatar

page archived

DT Agreements: Qatar - Income from a UK source paid to a resident of Qatar

page archived

DT Agreements: Qatar - Income from a UK source paid to a resident of Qatar

page archived

DT Agreements: Qatar - Income from a UK source paid to a resident of Qatar

page archived

DT Agreements: Qatar - Income from a UK source paid to a resident of Qatar

page archived

DT Agreements: Qatar - Income from a UK source paid to a resident of Qatar

page archived

DT Agreements: Qatar - Income from a UK source paid to a resident of Qatar

page archived

DT Agreements: Qatar - Income from a UK source paid to a resident of Qatar

page archived - reason added

page archived

DT Agreements: Qatar - Income from a UK source paid to a resident of Qatar

page archived

DT Agreements: Qatar - Income from a UK source paid to a resident of Qatar

page archived

DT Agreements: Qatar - Income from a UK source paid to a resident of Qatar

page archived

DT Agreements: Qatar - Income from a UK source paid to a resident of Qatar

page archived

DT Agreements: South Africa - Income from a UK source paid to a resident of South Africa

page archived

DT Agreements: South Africa - Income from a UK source paid to a resident of South Africa

page archived

DT Agreements: South Africa - Income from a UK source paid to a resident of South Africa

page archived

DT Agreements: South Africa - Income from a UK source paid to a resident of South Africa

page archived

DT Agreements: South Africa - Income from a UK source paid to a resident of South Africa

page archived

DT Agreements: South Africa - Income from a UK source paid to a resident of South Africa

page archived

DT Agreements: South Africa - Income from a UK source paid to a resident of South Africa

page archived

DT Agreements: South Africa - Income from a UK source paid to a resident of South Africa

page archived

DT Agreements: South Africa - Income from a UK source paid to a resident of South Africa

page archived

DT Agreements: South Africa - Income from a UK source paid to a resident of South Africa

page archived

DT Agreements: South Africa - Income from a UK source paid to a resident of South Africa

page archived

19 August 2019 published amendments

DT Agreements: New Zealand - Income from a UK source paid to a resident of New Zealand

PAGE archived

DT Agreements: New Zealand - Income from a UK source paid to a resident of New Zealand

page archived

DT Agreements: Norway - Income from a UK source paid to a resident of Norway

page archived

DT Agreements: Norway - Income from a UK source paid to a resident of Norway

page archived

DT Agreements: Norway - Income from a UK source paid to a resident of Norway

page archived

DT Agreements: Norway - Income from a UK source paid to a resident of Norway

page archived

DT Agreements: Norway - Income from a UK source paid to a resident of Norway

page archived

DT Agreements: Norway - Income from a UK source paid to a resident of Norway

page archived

DT Agreements: Norway - Income from a UK source paid to a resident of Norway

page archived

DT Agreements: Norway - Income from a UK source paid to a resident of Norway

page archived

DT Agreements: Pakistan - Income from a UK source paid to a resident of Pakistan

page archived

DT Agreements: Pakistan - Income from a UK source paid to a resident of Pakistan

page archived

DT Agreements: Pakistan - Income from a UK source paid to a resident of Pakistan

page archived

DT Agreements: Pakistan - Income from a UK source paid to a resident of Pakistan

page archived

DT Agreements: Pakistan - Income from a UK source paid to a resident of Pakistan

page archived

DT Agreements: Pakistan - Income from a UK source paid to a resident of Pakistan

page archived

DT Agreements: Pakistan - Income from a UK source paid to a resident of Pakistan

page archived

DT Agreements: Pakistan - Income from a UK source paid to a resident of Pakistan

page archived

DT Agreements: Pakistan - Income from a UK source paid to a resident of Pakistan

page archived

DT Agreements: Pakistan - Income from a UK source paid to a resident of Pakistan

page archived

DT Agreements: Pakistan - Income from a UK source paid to a resident of Pakistan

page archived

DT Agreements: Pakistan - Income from a UK source paid to a resident of Pakistan

page archived

DT Agreements: Pakistan - Income from a UK source paid to a resident of Pakistan

page archived

DT Agreements: Pakistan - Income from a UK source paid to a resident of Pakistan

page archived

DT Agreements: Portugal - Income from a UK source paid to a resident of Portugal

page archived

DT Agreements: Portugal - Income from a UK source paid to a resident of Portugal

page archived

16 August 2019 published amendments

DT Agreements: Netherlands - Income from a UK source paid to a resident of Netherlands

page archived

DT Agreements: New Zealand - Income from a UK source paid to a resident of New Zealand

page archived

DT Agreements: New Zealand - Income from a UK source paid to a resident of New Zealand

page archived

DT Agreements: New Zealand - Income from a UK source paid to a resident of New Zealand

page archived

DT Agreements: Netherlands - Income from a UK source paid to a resident of the Netherlands

page archived

DT Agreements: New Zealand - Income from a UK source paid to a resident of New Zealand

page archived

DT Agreements: New Zealand - Income from a UK source paid to a resident of New Zealand

page archived

DT Agreements: New Zealand - Income from a UK source paid to a resident of New Zealand

page archived

DT Agreements: Norway - Income from a UK source paid to a resident of Norway

page archived

DT Agreements: Norway - Income from a UK source paid to a resident of Norway

page archived

DT Agreements: New Zealand - Income from a UK source paid to a resident of New Zealand

page archived

DT Agreements: Norway - Income from a UK source paid to a resident of Norway

page archived

DT Agreements: New Zealand - Income from a UK source paid to a resident of New Zealand

page archived

DT Agreements: Netherlands - Income from a UK source paid to a resident of Netherlands

page archived

DT Agreements: Norway - Income from a UK source paid to a resident of Norway

page archived

DT Agreements: New Zealand - Income from a UK source paid to a resident of New Zealand

page archived

DT Agreements: New Zealand - Income from a UK source paid to a resident of New Zealand

page archived

DT Agreements: Norway - Income from a UK source paid to a resident of Norway

page archived

DT Agreements: Norway - Income from a UK source paid to a resident of Norway

page archived

DT Agreements: Norway - Income from a UK source paid to a resident of Norway

page archived

15 August 2019 published amendments

DT Agreements: Luxembourg - Income from a UK source paid to a resident of Luxembourg

page archived

DT Agreements: Luxembourg - Income from a UK source paid to a resident of Luxembourg

page archived

DT Agreements: Luxembourg - Income from a UK source paid to a resident of Luxembourg

page archived

DT Agreements: Luxembourg - Income from a UK source paid to a resident of Luxembourg

page archived

DT Agreements: Malta - Income from a UK source paid to a resident of Malta

page archived

DT Agreements: Malta - Income from a UK source paid to a resident of Malta

page archived

DT Agreements: Malta - Income from a UK source paid to a resident of Malta

page archived

DT Agreements: Malta - Income from a UK source paid to a resident of Malta

page archived

DT Agreements: Malta - Income from a UK source paid to a resident of Malta

page archived

DT Agreements: Malta - Income from a UK source paid to a resident of Malta

page archived

DT Agreements: Malta - Income from a UK source paid to a resident of Malta

page archived

DT Agreements: Malta - Income from a UK source paid to a resident of Malta

page archived

DT Agreements: Malta - Income from a UK source paid to a resident of Malta

page archived

DT Agreements: Malta - Income from a UK source paid to a resident of Malta

page archived

DT Agreements: Malta - Income from a UK source paid to a resident of Malta

page archived

DT Agreements: Malta - Income from a UK source paid to a resident of Malta

page archived

DT Agreements: Malta - Income from a UK source paid to a resident of Malta

page archived

DT Agreements: Malta - Income from a UK source paid to a resident of Malta

page archived

DT agreements - Income from a UK source paid to a resident of Martinique

page archived

DT Agreements: Netherlands - Income from a UK source paid to a resident of Netherlands

page archived

DT Agreements: Netherlands - Income from a UK source paid to a resident of Netherlands

page archived

DT Agreements: Japan - Income from a UK source paid to a resident of Japan

page archived

DT Agreements: Netherlands - Income from a UK source paid to a resident of Netherlands

page archived

DT Agreements: Netherlands - Income from a UK source paid to a resident of Netherlands

page archived

DT Agreements: Netherlands - Income from a UK source paid to a resident of Netherlands

page archived

DT Agreements: Netherlands - Income from a UK source paid to a resident of Netherlands

page archived

DT Agreements: Netherlands - Income from a UK source paid to a resident of Netherlands

page archived

DT Agreements: Netherlands - Income from a UK source paid to a resident of Netherlands

page archived

DT Agreements: Netherlands - Income from a UK source paid to a resident of Netherlands

page archived

DT Agreements: Netherlands - Income from a UK source paid to a resident of Netherlands

page archived - reason added

DT Agreements: Netherlands - Income from a UK source paid to a resident of Netherlands

page archived

14 August 2019 published amendments

DT Agreements: Japan - Income from a UK source paid to a resident of Japan

page archived

DT Agreements: Japan - Income from a UK source paid to a resident of Japan

page archived

DT Agreements: Japan - Income from a UK source paid to a resident of Japan

page archived

DT Agreements: Japan - Income from a UK source paid to a resident of Japan

page archived

DT Agreements: Japan - Income from a UK source paid to a resident of Japan

page archived

DT Agreements: Japan - Income from a UK source paid to a resident of Japan

page archived

DT Agreements: Japan - Income from a UK source paid to a resident of Japan

page archived

DT Agreements: Japan - Income from a UK source paid to a resident of Japan

page archived

DT Agreements: Japan - Income from a UK source paid to a resident of Japan

page archived

DT Agreements: Japan - Income from a UK source paid to a resident of Japan

page archived

Double Taxation Agreements: Jersey: Income from a UK source paid to a resident of Jersey - Contents

page archived

Double Taxation Agreements: Jersey: Income from a UK source paid to a resident of Jersey - Country code

page archived

Double Taxation Agreements: Jersey: Income from a UK source paid to a resident of Jersey - Application/claim forms

page archived

Double Taxation Agreements: Jersey: Income from a UK source paid to a resident of Jersey - Double taxation Agreements between the UK and Jersey

page archived

Double Taxation Agreements: Jersey: Income from a UK source paid to a resident of Jersey - Scope of the UK/Jersey Double Taxation Arrangement

page archived

Double Taxation Agreements: Jersey: Income from a UK source paid to a resident of Jersey - Industrial or commercial profits paragraph

page archived

Double Taxation Agreements: Jersey: Income from a UK source paid to a resident of Jersey - UK government pensions

page archived

Double Taxation Agreements: Jersey: Income from a UK source paid to a resident of Jersey - UK personal allowances

page archived

DT Agreements: Luxembourg - Income from a UK source paid to a resident of Luxembourg

page archived

DT Agreements: Luxembourg - Income from a UK source paid to a resident of Luxembourg

page archived

DT Agreements: Luxembourg - Income from a UK source paid to a resident of Luxembourg

page archived

DT Agreements: Luxembourg - Income from a UK source paid to a resident of Luxembourg

page archived - reason added

page archived

DT Agreements: Luxembourg - Income from a UK source paid to a resident of Luxembourg

page archived

DT Agreements: Luxembourg - Income from a UK source paid to a resident of Luxembourg

page archived

DT Agreements: Luxembourg - Income from a UK source paid to a resident of Luxembourg

page archived

DT Agreements: Luxembourg - Income from a UK source paid to a resident of Luxembourg

page archived

DT Agreements: Luxembourg - Income from a UK source paid to a resident of Luxembourg

page archived

DT Agreements: Luxembourg - Income from a UK source paid to a resident of Luxembourg

page archived

DT Agreements: Luxembourg - Income from a UK source paid to a resident of Luxembourg

page archived

13 August 2019 published amendments

DT Agreements: Jamaica - Income from a UK source paid to a resident of Jamaica

page archived

DT Agreements: Jamaica - Income from a UK source paid to a resident of Jamaica

page archived

DT Agreements: Jamaica - Income from a UK source paid to a resident of Jamaica

page archived

DT Agreements: Jamaica - Income from a UK source paid to a resident of Jamaica

page archived

DT Agreements: Jamaica - Income from a UK source paid to a resident of Jamaica

page archived

DT Agreements: Jamaica - Income from a UK source paid to a resident of Jamaica

page archived

DT Agreements: Jamaica - Income from a UK source paid to a resident of Jamaica

page archived

DT Agreements: Jamaica - Income from a UK source paid to a resident of Jamaica

page archived

DT Agreements: Jamaica - Income from a UK source paid to a resident of Jamaica

page archived

DT Agreements: Jamaica - Income from a UK source paid to a resident of Jamaica

page archived

DT Agreements: Jamaica - Income from a UK source paid to a resident of Jamaica

page archived

DT Agreements: Jamaica - Income from a UK source paid to a resident of Jamaica

page archived

DT Agreements: Jamaica - Income from a UK source paid to a resident of Jamaica

page archived

DT Agreements: Jamaica - Income from a UK source paid to a resident of Jamaica

page archived

DT Agreements: Jamaica - Income from a UK source paid to a resident of Jamaica

page archived

DT Agreements: Japan - Income from a UK source paid to a resident of Japan

page archived

DT Agreements: Japan - Income from a UK source paid to a resident of Japan

page archived - reason added

page archived

DT Agreements: Japan - Income from a UK source paid to a resident of Japan

page archived

DT Agreements: Japan - Income from a UK source paid to a resident of Japan

page archived

DT Agreements: Japan - Income from a UK source paid to a resident of Japan

page archived

DT Agreements: Japan - Income from a UK source paid to a resident of Japan

page archived

9 August 2019 published amendments

DT Agreements: Ireland - Income from a UK source paid to a resident of Ireland

page archived

DT Agreements: Ireland - Income from a UK source paid to a resident of Ireland

page archived

DT Agreements: Ireland - Income from a UK source paid to a resident of Ireland

page archived

DT Agreements: Ireland - Income from a UK source paid to a resident of Ireland

page archived

DT Agreements: Ireland - Income from a UK source paid to a resident of Ireland

page archived

DT Agreements: Ireland - Income from a UK source paid to resident of Ireland

page archived

DT Agreements: Ireland - Income from a UK source paid to a resident of Ireland

page archived

DT Agreements: Ireland - Income from a UK source paid to a resident of Ireland

page archived

DT Agreements: Ireland - Income from a UK source paid to a resident of Ireland

page archived

DT Agreements: Ireland - Income from a UK source paid to a resident of Ireland

page archived

DT Agreements: Ireland - Income from a UK source paid to a resident of Ireland

page archived

DT Agreements: Ireland - Income from a UK source paid to a resident of Ireland

page archived

DT Agreements: Ireland - Income from a UK source paid to a resident of Ireland

page archived

Double Taxation Agreements: Isle of Man: Income from a UK source paid to a resident of the Isle of Man - Contents

page archived

Double Taxation Agreements: Isle of Man: Income from a UK source paid to a resident of the Isle of Man - Country code

page archived

Double Taxation Agreements: Isle of Man: Income from a UK source paid to a resident of the Isle of Man - Application/claim forms

page archived

Double Taxation Agreements: Isle of Man: Income from a UK source paid to a resident of the Isle of Man - Double Taxation Agreements between the UK and the Isle of Man

page archived

Double Taxation Agreements: Isle of Man: Income from a UK source paid to a resident of the Isle of Man - Scope of the UK/Isle of Man Double Taxation Arrangement

page archived

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

page archived

Double Taxation Agreements: Isle of Man: Income from a UK source paid to a resident of the Isle of Man - UK government pensions

page archived

Double Taxation Agreements: Isle of Man: Income from a UK source paid to a resident of the Isle of Man - UK personal allowances

page archived

5 August 2019 published amendments

Transfer Pricing: methodologies: Mutual Agreement Procedure: HMRC contacts

contact details updated

Double Taxation Agreements: Guernsey: Income from a UK source paid to a resident of Guernsey - Country code

page archived

Double Taxation Agreements: Guernsey: Income from a UK source paid to a resident of Guernsey - Application/claim forms

page archived

Double Taxation Agreements: Guernsey: Income from a UK source paid to a resident of Guernsey - Double Taxation Agreements between the UK and Guernsey

page archived

Double Taxation Agreements: Guernsey: Income from a UK source paid to a resident of Guernsey - Scope of the UK/Guernsey Double Taxation Arrangement

page archived

Double Taxation Agreements: Guernsey: Income from a UK source paid to a resident of Guernsey - Industrial or commercial profits paragraph

page archived

Double Taxation Agreements: Guernsey: Income from a UK source paid to a resident of Guernsey - UK government pensions

page archived

Double Taxation Agreements: Guernsey: Income from a UK source paid to a resident of Guernsey - UK personal allowances

page archived

DT agreements: Guyane (French Guyana) - Income from a UK source paid to a resident of Guyane (French Guyana)

page archived

DT Agreements: Hong Kong - Income from a UK source paid to a resident of Hong Kong

page archived

DT Agreements: Hong Kong - Income from a UK source paid to a resident of Hong Kong

page archived

DT Agreements: Hong Kong - Income from a UK source paid to a resident of Hong Kong

page archived

DT Agreements: Hong Kong - Income from a UK source paid to a resident of Hong Kong

page archived

DT Agreements: Hong Kong - Income from a UK source paid to a resident of Hong Kong

page archived

DT Agreements: Hong Kong - Income from a UK source paid to a resident of Hong Kong

page archived

DT Agreements: Hong Kong - Income from a UK source paid to a resident of Hong Kong

page archived

DT Agreements: Hong Kong - Income from a UK source paid to a resident of Hong Kong

page archived

DT Agreements: Hong Kong - Income from a UK source paid to a resident of Hong Kong

page archived

DT Agreements: Hong Kong - Income from a UK source paid to a resident of Hong Kong

page archived

DT Agreements: Hong Kong - Income from a UK source paid to a resident of Hong Kong

page archived

DT Agreements: Iceland - Income from a UK source paid to a resident of Iceland

page archived

DT Agreements: Iceland - Income from a UK source paid to a resident of Iceland

page archived

DT Agreements: Iceland - Income from a UK source paid to a resident of Iceland

page archived

DT Agreements: Iceland - Income from a UK source paid to a resident of Iceland

page archived

DT Agreements: Iceland - Income from a UK source paid to a resident of Iceland

page archived

DT Agreements: Iceland - Income from a UK source paid to a resident of Iceland

page archived

DT Agreements: Iceland - Income from a UK source paid to a resident of Iceland

page archived

30 July 2019 published amendments

DT Agreements: Germany - Income from a UK source paid to a resident of Germany

page archived

DT Agreements: Germany - Income from a UK source paid to a resident of Germany

page archived

DT Agreements: Germany - Income from a UK source paid to a resident of Germany

page archived

DT Agreements: Germany - Income from a UK source paid to a resident of Germany

page archived

DT Agreements: Germany - Income from a UK source paid to a resident of Germany

page archived

DT Agreements: Germany - Income from a UK source paid to a resident of Germany

page archived

DT Agreements: Germany - Income from a UK source paid to a resident of Germany

page archived

DT Agreements: Germany - Income from a UK source paid to a resident of Germany

page archived

DT Agreements: Germany - Income from a UK source paid to a resident of Germany

page archived

DT Agreements: Germany - Income from a UK source paid to a resident of Germany

page archived

DT Agreements: Germany - Income from a UK source paid to a resident of Germany

page archived

DT Agreements: Germany - Income from a UK source paid to a resident of Germany

page archived

page archived

DT Agreements: Germany - Income from a UK source paid to a resident of Germany

page archived

DT Agreements: Germany - Income from a UK source paid to a resident of Germany

page archived

DT Agreements: Germany - Income from a UK source paid to a resident of Germany

page archived

DT Agreements: Guadeloupe - Income from a UK source paid to a resident of Guadeloupe

page archived

Double Taxation Agreements: Guernsey: Income from a UK source paid to a resident of Guernsey: Contents

page archived

29 July 2019 published amendments

DT Agreements: Denmark - Income from a UK source paid to a resident of Denmark

page archived

DT Agreements: Denmark - Income from a UK source paid to a resident of Denmark

page archived

DT Agreements: Denmark - Income from a UK source paid to a resident of Denmark

page archived

DT Agreements: Denmark - Income from a UK source paid to a resident of Denmark

page archived

DT Agreements: Denmark - Income from a UK source paid to a resident of Denmark

page archived

DT Agreements: Denmark - Income from a UK source paid to a resident of Denmark

page archived

DT Agreements: Denmark - Income from a UK source paid to a resident of Denmark

page archived

DT Agreements: Denmark - Income from a UK source paid to a resident of Denmark

page archived

DT Agreements: Denmark - Income from a UK source paid to a resident of Denmark

page archived

European Union: procedures: Staff based in the UK

page archived

DT Agreements: Finland - Income from a UK source paid to a resident of Finland

page archived

DT Agreements: Finland - Income from a UK source paid to a resident of Finland

page archived

DT Agreements: Finland - Income from a UK source paid to a resident of Finland

page archived

DT Agreements: Finland - Income from a UK source paid to a resident of Finland

page archived

DT Agreements: Finland - Income from a UK source paid to a resident of Finland

page archived

DT Agreements: Finland - Income from a UK source paid to a resident of Finland

page archived

DT Agreements: Finland - Income from a UK source paid to a resident of Finland

page archived

DT Agreements: Finland - Income from a UK source paid to a resident of Finland

page archived

DT Agreements: Finland - Income from a UK source paid to a resident of Finland

page archived

DT Agreements: Finland - Income from a UK source paid to a resident of Finland

page archived

DT Agreements: Finland - Income from a UK source paid to a resident of Finland

page archived

DT Agreements: Finland - Income from a UK source paid to a resident of Finland

page archived

DT Agreements: Finland - Income from a UK source paid to a resident of Finland

page archived

DT Agreements: Finland - Income from a UK source paid to a resident of Finland

page archived

DT Agreements: France - Income from a UK source paid to a resident of France

page archived

DT Agreements: France - Income from a UK source paid to a resident of France

page archived

DT Agreements: France - Income from a UK source paid to a resident of France

page archived

DT Agreements: France - Income from a UK source paid to a resident of France

page archived

DT Agreements: France - Income from a UK source paid to a resident of France

page archived

DT Agreements: France - Income from a UK source paid to a resident of France

page archived

DT Agreements: France - Income from a UK source paid to a resident of France

page archived

DT Agreements: France - Income from a UK source paid to a resident of France

page archived

DT Agreements: France - Income from a UK source paid to a resident of France

page archived

DT Agreements: France - Income from a UK source paid to a resident of France

page archived

DT Agreements: France - Income from a UK source paid to a resident of France: UK dividends paid to a resident of France - portfolio investor

page archived

DT Agreements: France - Income from a UK source paid to a resident of France

page archived

DT Agreements: France - Income from a UK source paid to a resident of France

page archived

DT Agreements: France - Income from a UK source paid to a resident of France: UK Government pensions paid to a resident of France

page archived

page archived

DT Agreements: France - Income from a UK source paid to a resident of France

page archived

DT Agreements: France - Income from a UK source paid to a resident of France

page archived

DT Agreements: France - Income from a UK source paid to a resident of France

page archived

24 July 2019 published amendments

DT Agreements: Canada - Income from a UK source paid to a resident of Canada

page archived

DT Agreements: Canada - Income from a UK source paid to a resident of Canada

page archived

DT Agreements: Canada - Income from a UK source paid to a resident of Canada

page archived

DT Agreements: Canada - Income from a UK source paid to a resident of Canada

page archived

DT Agreements: Cayman Islands: Income from a UK source paid to a resident of the Cayman Islands: Contents

page archived

DT Agreements: Cayman Islands: Income from a UK source paid to a resident of the Cayman Islands - Application forms

page archived

DT Agreements: Cayman Islands: Income from a UK source paid to a resident of the Cayman Islands - Double Taxation Agreement between the UK and the Cayman Islands

page archived

DT Agreements: Cayman Islands: Income from a UK source paid to a resident of the Cayman Islands - UK pensions/annuities paid to a resident of the Cayman Islands

page archived

DT Agreements: Cayman Islands: Income from a UK source paid to a resident of the Cayman Islands - Dividends, interest & royalties paid to a resident of the Cayman Islands

page archived

DT Agreements: Cayman Islands: Income from a UK source paid to a resident of the Cayman Islands - UK personal allowances

page archived

DT Agreements: Cyprus - Income from a UK source paid to a resident of Cyprus

page archived

DT Agreements: Cyprus - Income from a UK source paid to a resident of Cyprus

page archived

DT Agreements: Cyprus - Income from a UK source paid to a resident of Cyprus

page archived

DT Agreements: Cyprus - Income from a UK source paid to a resident of Cyprus

page archived

DT Agreements: Cyprus - Income from a UK source paid to a resident of Cyprus

page archived

DT Agreements: Cyprus - Income from a UK source paid to a resident of Cyprus

page archived

23 July 2019 published amendments

DT Agreements: British Virgin Islands - Income from a UK source paid to a resident of the British Virgin Islands (BVI)

page archived

DT Agreements: British Virgin Islands - Income from a UK source paid to a resident of the British Virgin Islands (BVI)

page archived

DT Agreements: British Virgin Islands - Income from a UK source paid to a resident of the British Virgin Islands (BVI)

page archived

DT Agreements: British Virgin Islands - Income from a UK source paid to a resident of the British Virgin Islands (BVI)

page archived

DT Agreements: British Virgin Islands - Income from a UK source paid to a resident of the British Virgin Islands (BVI)

page archived

DT Agreements: British Virgin Islands - Income from a UK source paid to a resident of the British Virgin Islands (BVI)

page archived

DT Agreements: Canada - Income from a UK source paid to resident of Canada

page archived

DT Agreements: Canada - Income from a UK source paid to a resident of Canada

page archived

DT Agreements: Canada - Income from a UK source paid to a resident of Canada

page archived

DT Agreements: Canada - Income from a UK source paid to a resident of Canada

page archived

DT Agreements: Canada - Income from a UK source paid to a resident of Canada

page archived

DT Agreements: Canada - Income from a UK source paid to a resident of Canada

page archived

DT Agreements: Canada - Income from a UK source paid to a resident of Canada

page archived

DT Agreements: Canada - Income from a UK source paid to a resident of Canada

page archived

DT Agreements: Canada - Income from a UK source paid to a resident of Canada

page archived

DT Agreements: Canada - Income from a UK source paid to a resident of Canada

page archived

DT Agreements: Canada - Income from a UK source paid to a resident of Canada

page archived

22 July 2019 published amendments

DT Agreements: Australia - Income from a UK source paid to a resident of Australia

Page archived

DT Agreements: Australia - Income from a UK source paid to a resident of Australia

page archived

DT Agreements: Austria - Income from a UK source paid to a resident of Austria

archving - reason text added

DT Agreements: Australia - Income from a UK source paid to a resident of Australia

page archived

DT Agreements: Australia - Income from a UK source paid to a resident of Australia

page archived

DT Agreements: Australia - Income from a UK source paid to a resident of Australia

PAGE ARCHIVED

DT Agreements: Australia - Income from a UK source paid to a resident of Australia

Page archived

DT Agreements: Australia - Income from a UK source paid to a resident of Australia

page archived

DT Agreements: Australia - Income from a UK source paid to a resident of Australia

PAGE ARCHIVED

DT Agreements: Australia - Income from a UK source paid to a resident of Australia

PAGE ARCHIVED

DT Agreements: Australia - Income from a UK source paid to a resident of Australia

PAGE ARCHIVED

DT Agreements: Australia - Income from a UK source paid to a resident of Australia

PAGE ARCHIVED

DT Agreements: Australia - Income from a UK source paid to a resident of Australia

PAGE ARCHIVED

DT Agreements: Australia - Income from a UK source paid to a resident of Australia

PAGE ARCHIVED

DT Agreements: Australia - Income from a UK source paid to a resident of Australia

PAGE ARCHIVED

DT Agreements: Australia - Income from a UK source paid to a resident of Australia

page archived

DT Agreements: Austria - Income from a UK source paid to a resident of Austria

PAGE ARCHIVED

DT Agreements: Austria - Income form a UK source paid to a resident of Austria

PAGE ARCHIVED

DT Agreements: Austria - Income from a UK source paid to a resident of Austria

PAGE ARCHIVED

DT Agreements: Austria - Income from a UK source paid to a resident of Austria

page archived

DT Agreements: Austria - Income from a UK source paid to a resident of Austria

PAGE ARCHIVED

DT Agreements: Austria - Income from a UK source paid to a resident of Austria

page archived

DT Agreements: Austria - Income from a UK source paid to a resident of Austria

page archived

DT Agreements: Austria - Income from a UK source paid to a resident of Austria

PAGE ARCHIVED

DT Agreements: Austria - Income from a UK source paid to a resident of Austria

PAGE ARCHIVED

DT Agreements: Austria - Income from a UK source paid to a resident of Austria

page archived

DT Agreements: Austria - Income from a UK source paid to a resident of Austria

page archived

8 July 2019 published amendments

Double Taxation applications and claims: foundations, establishments and associations: Action required - refer to CSTD, Business, Assets & International, Assets Residence & Valuation

update contact details

Double Taxation applications and claims - Exchange of information and correspondence with overseas tax authorities: Claims for non-DT income

update contact details

Double Taxation applications and claims: Vouchers: Block vouchers issued by Irish banks

contact details changed

Double Taxation applications and claims: applicants/claimants: International associations: What relief international associations can claim from HMRC

contact details changed

Double Taxation applications and claims: Repayment claims from non-residents: Enquiries: What to do if it is too late to issue a notice of intention to enquire into a claim

change of contact details

Double Taxation applications and claims: Applicants/claimants: Estates and deceased persons: Laws of Intestacy

contact details changed

Double Taxation applications and claims: relief at source over-allowed: Recovery of tax where relief at source has been over-allowed

contact details changed

Double Taxation applications and claims: Vouchers: What to do if you suspect a voucher has been altered

contact details changed

Double Taxation applications and claims: Applicants/claimants: Claims by financial concerns under Business Profits Articles: Claims by Channel Islands and Isle of Man banks

contact details changed

Double Taxation applications and claims: Repayment claims from non-residents: Enquiries: Protective enquiries

contact details changed

Double Taxation applications and claims: Applicants/claimants: Estates and deceased persons: What happens if there is no Grant of Probate

contact details changed

Double Taxation Applications and Claims: companies: How to tell that a claim is from a company

contact details changed

Double Taxation applications and claims: companies: What you do on receipt of a completed questionnaire 2300Q

contact details changed

Double Taxation applications and claims - Exchange of information and correspondence with overseas tax authorities: If the overseas tax authorities dispute a decision

contact details changed

Double Taxation applications and claims: time limit: Questions about an extension to the time limit

contact details changed

Double Taxation applications and claims: signature of declarations: Who should sign the declaration - companies

contact details changed

Double Taxation applications and claims: Repayment claims from non-residents: closing an enquiry: What to do before closing an enquiry

contact details changed

Double taxation agreements: residence: Individuals

contact details changed

Double Taxation applications and claims: time limit: Challenges to application of time limit

contact details changed

Double Taxation applications and claims: Repayment claims from non-residents: Enquiries: What to do before you open an enquiry

contact details changed

7 June 2019 published amendments

23 May 2019 published amendments

Profit Fragmentation Adjustments

change from draft to published

Profit Fragmentation Adjustments: Reimbursement Payments

change from draft to published

21 May 2019 published amendments

10 May 2019 published amendments

1 May 2019 published amendments

11 February 2019 published amendments

International Manual

change email address

31 January 2019 published amendments

29 January 2019 published amendments

Double Taxation applications and claims: Vouchers: Common types of voucher

hyperlink added

removal of actual document

MINOR FORMAT CHANGE

28 January 2019 published amendments

21 January 2019 published amendments

18 January 2019 published amendments

8 January 2019 published amendments

2018

14 December 2018 published amendments

Company residence: 'Treaty non-resident' companies

major update to page

Company residence: residence under foreign law

Hyperlink change

Double taxation: concept and principles: UK enabling legislation - relief under double taxation agreements

Hyperlink change

UK residents with foreign income or gains: certificates of residence: What HMRC will check - reason and date for which certification is required

removed external link to DT2140, as the link was already publicly available

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

Link fixed

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

link change

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

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: 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: Transfer pricing adjustments in the context of Chapter 9

text change

Controlled Foreign Companies: Relevant Interests in a CFC: Other Relevant Interests

Page republished

Controlled Foreign Companies: How the corporate tax regime works for CFCs: Clearances: General

Change from CRM to CCM

Non-residents trading in the UK: permanent establishment: domestic and treaty law: Introduction

Page content replaced as part of revamp of International manual.

Non-residents trading in the UK: Treaty law could potentially affect the UK domestic charge to tax: Treaty law - an introduction

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

text change

Double Taxation applications and claims - Introduction: Scope of this guidance

additional section on exchange of information added

Double Taxation applications and claims: applicants/claimants: International associations: What the difference is between an international association and an international organisation

Hyperlink update

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: 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

Double Taxation Agreements: Jersey: Income from a UK source paid to a resident of Jersey - Industrial or commercial profits paragraph

Hyperlink & text change

EU Directive: Interest & Royalties paid between Associated Companies - claims and applications by non- residents

broken link fixed

DT applications and claims: Non-resident beneficiaries of UK trusts

Hyperlink change

The Non-resident Landlords Scheme: How non-resident landlords can apply to get their UK rent paid gross

Hyperlink added

Interest and Royalty payments - overview

broken link

Transfer pricing: legislation: rules: introduction

Amendment to remove duplication of text

Transfer pricing: Methodologies: OECD Guidelines: Overview

slight change to wording under heading OECD Transfer Pricing Guidelines

Transfer pricing: Methodologies: OECD Guidelines: Comparability

Content updated re BEPS updates to OECD guidelines

Transfer pricing: Methodologies: OECD Guidelines: Cost contribution arrangements

minor content changes

Transfer pricing: Types of transactions: Services: introduction

Minor drafting amendments

Transfer pricing: Types of transactions: centrally provided services

Content updated re BEPS updates to OECD guidelines

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

change team name

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: profit split method

minor drafting amendments

Transfer pricing: Types of transactions: setting aside a provision between connected parties

change of team name

Transfer Pricing: Transactions and Structures: business structures: transferring risk

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: Operational guidance: real time working of transfer pricing issues (excluding thin capitalisation)

text change

Transfer pricing: operational guidance: working a transfer pricing case: assessments and enquiry closure notices

Republish to push changes through.

Transfer pricing operational guidance: Evidence gathering: Establish the facts

change of team name

Arbitrage: legislation and principles: procedures: Clearance procedures

email added

Transfer of assets abroad: Overview of ITA2007/Sections 721 and 727 (‘Income Charge’)

Hyperlink change

Distribution exemption: Interpretation: certain non-dividend distributions

broken link fixed

Transfer pricing: Methodologies: OECD Guidelines: Comparable uncontrolled price: Commodity Transactions

new page - BEPS update on OECD guidelines

Transfer Pricing: Types of transactions: Services: Low Value-Adding Services

BEPS update to OECD guidance

Transfer Pricing: Types of transactions: Intangibles: Establishing an arm's length price for valuable intangibles: Hard to Value Intangibles

minor formatting

Transfer pricing operational guidance: Accurate delineation of the actual transaction: Risk allocation

update diagrame attachment

Non-residents trading in the UK: Introduction: Introduction to the module

LINKS UPDATED

Non-residents trading in the UK: Introduction: Relevant legislation

...

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: Industry focus 1: e-commerce

formatting

Non-residents trading in the UK: permanent establishment: domestic and treaty law: Industry focus 2: building site or construction or installation project

formatting

Cash pooling: Introduction to cash pooling

updated live link

Cash pooling: Legal and commercial arrangements

update link

Cash pooling: UK company as the cash pool header and the arm’s length principle

updated new links

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: Claims

format change

12 December 2018 published amendments

26 November 2018 published amendments

19 November 2018 published amendments

UK residents with foreign income or gains: income arising abroad: Partnerships

link changes

UK residents with foreign income or gains: income arising abroad: Employment - double taxation

LINK CHANGE

UK residents with foreign income or gains: dividends: EC Directive

change link

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

REVISED LINKS

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

link updates

UK residents with foreign income or gains: corporation tax: Loan relationships

update link

UK residents with foreign income or gains: corporation tax: Loan relationships

link update

UK residents with foreign income or gains: corporation tax: Dividends: withholding tax

update link

UK residents with foreign income or gains: corporation tax: Intangible fixed assets

link updates

UK residents with foreign income or gains: capital gains tax: Gain taxed UK/abroad

broken link fixed

UK residents with foreign income or gains: capital gains tax: Remittance basis

link update

Controlled Foreign Companies: Introduction to the CFC Charge: Particular Entities: Companies which are managers of offshore funds

update links

Controlled Foreign Companies: Introduction to the CFC Charge: Particular Entities: Companies which are participants in offshore funds

LINK UPDATE

Controlled Foreign Companies: Introduction to the CFC Charge: Particular Entities: Companies holding shares as trading assets

LINK UPDATE

Format change

29 October 2018 published amendments

UK residents with foreign income or gains: certificates of residence: escalation routes for HMRC staff in cases of difficulty

redacted entirety as it contains internal contact information, and is aimed at HMRC staff only. Previously, the redaction message was repeated and left out portions of text which caused confusion.

Contact details update

1 October 2018 published amendments

28 September 2018 published amendments

Company residence: contents

minor change

change

24 September 2018 published amendments

Company residence: treaty tie-breakers and self-assessment

slight amendment

Company residence: standard treaty tie-breakers

title change

format change

minor change

minor change

19 July 2018 published amendments

16 July 2018 published amendments

UK residents with foreign income or gains: claims for double taxation relief against UK tax: time limits

Minor 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: double taxation relief: Lists of qualifying taxes

text change

Double taxation agreements: introduction: Interpretation of double taxation agreements

text change

Arbitrage: legislation and principles: procedures: Notices directing that the legislation will apply

text change

Arbitrage: practical guidance: case identification and working of enquiries: The arbitrage team in Business, Assets & International

Text change

Thin capitalisation: practical guidance: introduction: referrals to Business, Assets & International

Text change

Description of double taxation agreements: Capital gains

text change

Description of double taxation agreements: Independent personal services

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

Non-residents trading in the UK: introduction

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: Is there a charge under domestic legislation: Trading in the UK: Making a contract

Text change

Transfer pricing: operational guidance: working a transfer pricing case: assessments and enquiry closure notices

text change

UK residents with foreign income or gains: double taxation relief: ‘Tax spared’ credit

text change

Foreign banks trading in the UK through permanent establishments: Transfer of loans

text change

Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment managers: "investment transaction": transactions in relevant contracts

text change

minor change

22 June 2018 published amendments

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

added new pages to sub-index

INTM219370 and INTM219380 added to menu

Double Taxation applications and claims: applicants/claimants - individuals: Individuals entitled to UK personal allowances

various text changes

minor text change

Controlled Foreign Companies: The CFC Charge Gateway Chapter 4 - Profits attributable to UK activities: Case study

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 7 - captive Insurance Business: contracts of insurance falling within TIOPA10/S371GA(2)

Diagrams 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 9 - exemptions for profits from qualifying loan relationships: what is a qualifying loan relationship

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: Temporary Loan from the UK

Diagram updated

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: Revised Matched Interest Rule: Applying the exemption: Example 1

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 2

Added link to diagram

11 May 2018 published amendments

23 April 2018 published amendments

29 March 2018 published amendments

27 March 2018 published amendments

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

Minor change

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

International Manual

Change in contact 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

UK residents with foreign income or gains: certificates of residence: UK and overseas branches or permanent establishments

Change in 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

Controlled Foreign Companies: Apportionment of a CFC’s Chargeable Profits and Creditable Tax: Apportionment on a just and reasonable basis

Change of team name

Thin capitalisation: practical guidance: lending against asset values: offshore property companies

Change of team name

Controlled Foreign Companies: Entity Exemptions: Chapter 14 - The Tax Exemption: The Basic Rule

Change from CTIS to CSTD

Transfer pricing: methodologies: Advance Pricing Agreements: Sample agreement

Change of team name

Controlled Foreign Companies: The CFC Charge Gateway Chapter 6 - Trading Finance Profits: Capital requirements in the banking sector.

change in team name

UK residents with foreign income or gains: double taxation relief: Statutory income basis

change from CTISA to CTSD

UK residents with foreign income or gains: double taxation relief: Minimum foreign tax

change from CTISA to CSTD

22 March 2018 published amendments

How the corporate tax regime works for Controlled Foreign Companies: Clearances: where to send applications

Address change

Controlled Foreign Companies: legislation - introduction and outline: Guidance on the Controlled Foreign Companies’ rules under self assessment

Address change

Address change

Investment from abroad: Inward Investment Support

Address change

Address change

Address change

Controlled Foreign Companies: How the corporate tax regime works for CFCs: Clearances: Where to send applications

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

Controlled Foreign Companies: EEA states - deduction for net economic value against apportionment: Information to be included in applications under ICTA88/S751A

Address change

Arbitrage: legislation and principles: procedures: Clearance procedures

Address change

Arbitrage: practical guidance: case identification and working of enquiries: The arbitrage team in Business, Assets & International

Address change

Foreign Permanent Establishments of UK Companies: anti-diversion rule: Initial gateway filter - Does Chapter 4 apply?

Address change

UK residents with foreign income or gains: double taxation relief: Corresponding adjustments and the alternative method

Address change

Foreign tax paid on trade income: limitations on credit: 2009 legislation

Address change

Description of double taxation agreements: Mutual agreement procedure

Address change

Transfer Pricing: methodologies: Mutual Agreement Procedure: HMRC contacts

Address change

12 February 2018 published amendments

6 February 2018 published amendments

5 February 2018 published amendments

31 January 2018 published amendments

30 January 2018 published amendments

Transfer pricing: methodologies: Mutual Agreement Procedure: Arbitration

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: Links to other relevant documents

content updated for SOP 01/2018

Transfer Pricing: methodologies: Mutual Agreement Procedure: Introduction to MAP

change from CTIAA to CSTD

content updated for SOP 01/2018

Transfer Pricing: methodologies: Mutual Agreement Procedure: Eligibility for MAP

change from CTIAA to CSTD

content updated for SOP 01/2018

Transfer Pricing: methodologies: Mutual Agreement Procedure: Access to MAP

Change from CTIAA to CSTD

content updated for SOP 01/2018

Transfer Pricing: methodologies: Mutual Agreement Procedure: The MAP process continued

change from CTIAA to CSTD

content updated for SOP 01/2018

Transfer pricing: methodologies: Mutual Agreement Procedure: contents

new content added INTM423130

Transfer Pricing: methodologies: Mutual Agreement Procedure: The MAP process

content updated for SOP 01/2018

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

25 January 2018 published amendments

Thin capitalisation: practical guidance: introduction: referrals to 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

UK residents with foreign income or gains: double taxation relief: Referrals and reports to CSTD Business, Assets & International

change of 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: claims for double taxation relief against UK tax: disputed claims

change in 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

Controlled Foreign Companies: Reviews: Other considerations

change of team name

Thin capitalisation: practical guidance: introduction: getting help with thin capitalisation cases

change of team name

Transfer pricing: operational guidance: working a transfer pricing case: penalties

Change of team name

Description of double taxation agreements: Government service

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

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

Thin capitalisation: practical guidance: the Advance Thin Capitalisation Agreement process: Introduction to the ATCA process and its governance

change of team name

Company residence: the incorporation rule - commencement and transitional provisions

change of team name

Arbitrage: legislation and principles - deductions: interaction with other legislation

change team name

Controlled Foreign Companies: How the corporate tax regime works for CFCs: HMRC enquiries: records

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

Transfer pricing: Operational guidance: alternatives to consider before transfer pricing

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: Transactions and Structures: business structures: valuable intangibles

change team name

Thin capitalisation: practical guidance: the use of credit ratings: further considerations when using credit ratings in thin capitalisation cases

change team name

How the corporate tax regime works for Controlled Foreign Companies: HMRC enquiries: Commissioners’ sanction

change team name

Transfer pricing: the main thin capitalisation legislation: Introduction

change team name

Transfer pricing: operational guidance: working a transfer pricing case: penalties: negligence or carelessness

change team name

22 January 2018 published amendments

Controlled Foreign Companies: legislation - introduction and outline: Board’s notice of approval and rights of appeal

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

Thin capitalisation: practical guidance: accountancy issues: introduction: accountancy impact on thin capitalisation

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: the Advance Thin Capitalisation Agreement process: withdrawing from the ATCA process

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 use of credit ratings: in-house credit ratings

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: measuring debt: adjusting debt calculations: netting off of debt

change of team name

Transfer pricing: legislation: rules: exemptions: small and medium sized enterprises

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: operational guidance: governance: the selection stage

change of team name

Description of double taxation agreements: Shipping/air transport

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

Transfer Pricing: Transactions and Structures: business structures: research and development

change of team name

Transfer Pricing: Transactions and Structures: business structures: other legislation

change of team name

Transfer pricing: risk assessment: conducting a transfer pricing risk assessment: review of information from other sources

change of team name

Description of double taxation agreements: Permanent establishment

change of team name

Description of double taxation agreements: Taxes covered

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

Controlled Foreign Companies: legislation - introduction and outline: Interest and penalties

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: 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

19 January 2018 published amendments

Arbitrage: practical guidance: case identification and working of enquiries: submissions to the arbitrage team in CSTD Business, Assets & International

change of team name

Non-residents trading in the UK: place of contract may not be decisive

change of team name

Non-residents trading in the UK: making of contract

change of team name

UK residents with foreign income or gains: certificates of residence: Dual resident companies

change of team name

UK residents with foreign income or gains: certificates of residence: letter of confirmation

change of team name

Transfer pricing: operational guidance: working a transfer pricing case: Exchange of information

change of team name

UK residents with foreign income or gains: double taxation relief: The source rule - concessions

change from CTISA to CTSD

Technical guidance for Swiss/UK Tax Cooperation Agreement: Introduction: Background

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: UK legislation

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.

Clearance under the agreement: Overview

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: Eligible for clearance

Updates following termination of the Agreement.

Clearance under the agreement: Not eligible for clearance

Updates following termination of the Agreement.

Clearance under the agreement: Amounts not cleared: Overview

Updates following termination of the Agreement.

Examples: contents

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.

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: Tax obligations not cleared (the future)

Updates following termination of the Agreement.

Clearance under the agreement: Certificate

Updates following termination of the Agreement.

Examples: Effect of minimum rate & IHT

Updates following termination of the Agreement.

Examples: Increased one-off payment

Updates following termination of the Agreement.

Residence & non-UK domiciles: Residence

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: Formally disputed

Updates following termination of the Agreement.

Residence & non-UK domiciles: Effect of certificate

Updates following termination of the Agreement.

Other terminology: Life insurance - appropriate certification

Updates following termination of the Agreement.

Other terminology: Rate of withholding tax

Updates following termination of the Agreement.

18 January 2018 published amendments

Controlled Foreign Companies: Reviews: Reports to Business, Assets & International, Base Protection Policy Team

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

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: Clearance Procedures

change of team name

Company residence: the incorporation rule

change of team name

Controlled Foreign Companies: legislation - introduction and outline: Definition of Controlled Foreign Company

change of team name

Controlled Foreign Companies: Reviews: Working individual companies

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: definitions

change of team name

How the corporate tax regime works for Controlled Foreign Companies: HMRC enquiries: penalties

change team name

Controlled Foreign Companies: Reviews: Large groups - arrangements for handling Controlled Foreign Company Returns

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: definitions

change of team name

How the corporate tax regime works for Controlled Foreign Companies: HMRC enquiries: records

change of team name

17 January 2018 published amendments

Foreign Permanent Establishments of UK Companies: introduction: procedures

change from CTIAA to CSTD

Transfer Pricing: Transactions and Structures: business structures: other legislation

Change from CTIAA to CSTD

Exchange of information: Introduction to EOI and Requests

change from CTIAA to CSTD

UK residents with foreign income or gains: dividends: Dividend articles in double taxation agreements

change from CTIAA to CSTD

Transfer Pricing: Transactions and Structures: business structures: valuable intangibles

change from CTIAA to CSTD

Transfer pricing: operational guidance: working a transfer pricing case: transfer pricing documentation

Change from CTIAA to CSTD

Transfer pricing: operational guidance: governance: case teams and the wider transfer pricing community

change from CTIAA to CSTD

Double taxation treaties: Beneficial ownership: Practical consideration of claims

change from CTIAA to CSTD

Intra-group funding: group finance companies and the treasury function: Risk assessment

change from CTIAA to CSTD

Double taxation agreements: residence: Dual residents

change from CTIAA to CSTD

Thin capitalisation: practical guidance: lending against asset values: lending against tangible assets - land and buildings

slight paragraph amendment

UK residents with foreign income or gains: income arising abroad: Branch profits

change from CTIAA to CSTD

Foreign tax paid on trade income: limitations on credit: 2009 legislation

change from CTIAA to CSTD

Company residence: 'Treaty non-resident' companies

change from CTIAA to CSTD

Double taxation agreements: residence: Companies

Change from CTIAA to CSTD

change from CTIAA to CSTD

Arbitrage: practical guidance: case identification and working of enquiries: profiling for arbitrage cases

change from CTIAA to CSTD

Double taxation agreements: introduction: OECD and UN model agreements

change from CTIAA to CSTD

Transfer Pricing: Transactions and Structures: business structures: marketing and distribution - commissionaires: challenges

change from CTIAA to CSTD

Foreign tax paid on trade income: limitation on credit: 1998 legislation - detail

change from CTIAA to CSTD

Transfer pricing: operational guidance: working a transfer pricing case: penalties: negligence or carelessness

Change from CTIAA to CSTD

Transfer pricing: Types of transactions: intangibles: royalties

change from CTIAA to CSTD

UK residents with foreign income or gains: double taxation relief: Lists of qualifying taxes

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: certificates of residence: customised certificates of residence and side letters

change from CTISA 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: double taxation relief: Foreign tax

change from CTIAA to CSTD

UK residents with foreign income or gains: double taxation relief: Unilateral relief

change from CTIAA to CSTD

Thin capitalisation: practical guidance: the Advance Thin Capitalisation Agreement process: role of Business, Assets & International

change from CTISA to CSTD

16 January 2018 published amendments

Transfer pricing: Types of transactions: charities

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

Double Taxation applications and claims: Repayment claims from non-residents: closing an enquiry: Key points about closing an enquiry

change from CTIAA to CSTD

Exchange of information: Spontaneous exchanges

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

Double Taxation applications and claims: Repayment claims from non-residents: Enquiries: Key points about opening an enquiry

change from CTIAA to CSTD

UK residents with foreign income or gains: dividends: Underlying tax

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

EU Interest and Royalties Directive: Anti-avoidance measures

change from CTIAA to CSTD

Transfer pricing: the main thin capitalisation legislation: Borrowing capacity - the borrowing unit

change from CTIAA to CSTD

Transfer pricing: operational guidance: governance: the Transfer Pricing Group

Change from CTIAA to CSTD

UK residents with foreign income or gains: income arising abroad: Dividends

change from CTIAA to CSTD

UK residents with foreign income or gains: income arising abroad: Partnerships

change from CITAA to CSTD

Transfer pricing: legislation: rules: exemptions: small and medium sized enterprises

change from CTIAA to CSTD

Transfer pricing: operational guidance: working a transfer pricing case: assessments and enquiry closure notices

change from CTIAA to CSTD

Interest imputation: dealing with ‘equity function’ arguments: Issues affecting equity function cases

change from CTIAA to CSTD

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

change from CTIAA to CSTD

UK residents with foreign income or gains: income arising abroad: Definition of government remuneration

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

Company residence: standard treaty tie-breakers

change from CTIAA to CSTD

12 January 2018 published amendments

DT applications and claims: Crown Immunity, Sovereign Immunity and Diplomatic Privilege

Page archived

DT applications and claims: Crown Immunity, Sovereign Immunity and Diplomatic Privilege

Page archived

DT applications and claims: Crown Immunity, Sovereign Immunity and Diplomatic Privilege

Page archived

Sovereign and crown immunity

Page archived

UK residents with foreign income or gains: certificates of residence: information to be supplied with a request

Change CRM to CCM

Thin capitalisation: practical guidance: creating agreements between HMRC and the group: statement of practice 01/12

Change CRM to CCM

Transfer pricing: methodologies: Advance Pricing Agreements: monitoring and review

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

Cash pooling: UK company as long-term borrower in the cash pool

Change from CRM to CCM

Transfer pricing: methodologies: Advance Pricing Agreements: expression of interest

Change from CRM to CCM

Thin capitalisation: practical guidance: the Advance Thin Capitalisation Agreement process: renewing the ATCA

Change from CRM to CCM

Cash pooling: risk assessment/compliance checks

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

International movements of capital: Exclusions: cash pooling arrangements

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: The CFC Charge Gateway Chapter 6 - Trading Finance Profits: Factors relevant to the capitalisation of insurance companies

Change from CRM to CCM

DT applications and claims: Crown Immunity, Sovereign Immunity and Diplomatic Privilege: Contents

Page archived

Principles of double taxation relief and introduction to double taxation agreements: sovereign and crown immunity: contents

Page archived

Transfer pricing: operational guidance: governance: case teams and the wider transfer pricing community

Change CRM to CCM

International Manual: recent changes

Change from CRM to CCM

11 January 2018 published amendments

International movements of capital: Reporting requirement: where should reports be sent?

Changing CRM to CCM

Change 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

Arbitrage: practical guidance: case identification and working of enquiries: The arbitrage team in Business, Assets & International

Change from CRM to CCM

Transfer pricing: operational guidance: governance: the selection stage

Change 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: methodologies: Advance Pricing Agreements: formal application

Change from CRM to CCM

Transfer pricing: operational guidance: governance: the resolution stage

Change CRM to CCM

Transfer pricing: risk assessment: issues to consider before starting a transfer pricing enquiry: resources

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

Foreign Permanent Establishments of UK Companies: introduction: election for S18A to take effect

Change from CRM to CCM

Thin capitalisation: practical guidance: the Advance Thin Capitalisation Agreement process: completing the process

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

Transfer pricing: methodologies: Advance Pricing Agreements: what is an APA?

Change from CRM to CCM

Arbitrage: legislation and principles: procedures: Clearance procedures

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

Transfer pricing: operational guidance: governance: case teams and the wider transfer pricing community

Change from CRM to CCM

9 January 2018 published amendments

Immunities and Privileges: Contents

New section for International Manual

2017

1 December 2017 published amendments

30 November 2017 published amendments

Hybrid and other mismatches

minor title change

title change

minor title change

minor title change

minor change

minor change

title change

9 October 2017 published amendments

6 October 2017 published amendments

5 October 2017 published amendments

4 October 2017 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.

22 September 2017 published amendments

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

Non-residents trading in the UK: contents

New page added - INTM269510

20 September 2017 published amendments

8 August 2017 published amendments

29 March 2017 published amendments

Transfer pricing: methodologies: Advance Pricing Agreements: who may apply?

Changed numbering of paragraph to bullets. No text changes.

Changed numbering of paragraph to bullets. No text changes.

Numbers reordered

Transfer pricing: methodologies: Advance Pricing Agreements: expression of interest

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: reaching agreement

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.

23 March 2017 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

2 new sections added at the beginning to reflect legislative changes brought in by FA2015

new paras added a the start of the page to reflect legislative changes brought in by FA2015

21 March 2017 published amendments

6 February 2017 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

1 February 2017 published amendments

Arbitrage: legislation and principles: procedures: Clearance procedures

additional sectoin added on exchang of information.

EU Directive: Interest & Royalties paid between Associated Companies - claims and applications by non- residents

additional section on Exchange of Information added

Interest and Royalty payments - overview

additional section on Exchange of Information added

24 January 2017 published amendments

Transfer pricing: Operational guidance: alternatives to consider before transfer pricing

x

no change to text. just needed to publish as it had reverted to draft

23 January 2017 published amendments

19 January 2017 published amendments

PAGE WITHDRAWN 19/01/17

remove INTM269079 on 19/01/2017

PAGE WITHDRAWN 19/01/17

Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents - Contents

INTM269079 WITHDRAWN ON 19/01/17

INTM269079 removed / no longer valid from 19/01/17

2016

8 November 2016 published amendments

7 November 2016 published amendments

30 September 2016 published amendments

Transfer pricing: operational guidance: Evidence gathering: Index page: contents

BEPS updates to OECD guidelines

4 new pages - BEPS updates on OECD guidelines

Transfer prcing operational guidance: Accurate delineation of the actual transaction: Economically relevant characteristics

New page - BEPS update to OECD guidelines

Transfer pricing operational guidance: Accurate delineation of the actual transaction: Full process

new page - BEPS update to OECD guidelines

Transfer pricing: Methodologies: OECD Guidelines: contents

New page

Transfer pricing: Methodologies: OECD Guidelines: Overview

content updated re BEPS updates to OECD guidelines

Transfer pricing: Methodologies: OECD Guidelines: Cost contribution arrangements

content updated re BEPS updates to OECD guidelines

Transfer pricing: Types of transactions: Services: introduction

Contents 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: intangibles: what are intangibles?

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: fragmentation

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: 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: setting aside a provision between connected parties

content 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 operational guidance: Evidence gathering: Establish the facts

contents 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: 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

29 September 2016 published amendments

Transfer pricing: Types of transactions: contents

BEPS updates to OECD guidelines

3 new pages - BEPS updates to OECD guidance

3 new pages - BEPS updates to OECD guidance

Transfer Pricing: Types of transactions: Intangibles: Establishing an arm's length price for valuable intangibles: Hard to Value Intangibles

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