Updates: International Manual
2024
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.
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.
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.
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.
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.
Transfer pricing: legislation: rules: the arm's length principle
Updating link at the bottom of the page from INTM480020 to INTM480520.
Transfer pricing records: when to provide the specified transfer pricing records
Change authorised by Jenny Buchanan.
UK residents with foreign income or gains: income arising abroad: Partnerships
Replaced “s852” with “s858”.
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.
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
UK residents with foreign income or gains: income tax: Trades, professions set up 1996-97 onwards
Updates made to guidance pages in relation to Basis Period Reform
UK residents with foreign income or gains: income tax: Overlap profits
Updates made to guidance pages in relation to Basis Period Reform
UK residents with foreign income or gains: double taxation relief: Foreign tax
Updates made to guidance pages in relation to Basis Period Reform
Examples updated for page
updated list of countries and updated date it takes effect from
Changing Ian Provan to Nayem Husain.
Contact details changed to certificates of residence mailbox
UK residents with foreign income or gains: certificates of residence: letter of confirmation
Adding sentence to tell customers how to apply for a LOC.
Various changes agreed by Martin Voelker of the TP Team.
Company residence: Statement of Practice 1/90
Minor spelling correction - nusiness to business.
Double Taxation applications and claims: time limit: Notice of intention to claim
Last paragraph updated to reflect MAP request to mailbox.
Non-residents trading in the UK: Introduction: Introduction to the module
updated 2nd paragraph
amended typos
Removal of reference to Hong Kong.
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.
DT applications and claims - Types of income: Interest
Changing outdated legislation
Change requested by policy lead Rufus Rottenberg.
European Union (EU): General Exemption
Page archived
European Union: exemption from Taxation
Updated paragraph to detail terms of exemption
Employees of International Organisations: Experts/consultants
Chnage requested by pag eowner Rufus Rottenberg.
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).
Updated CFCs Mailbox link to correct address; updated postal address
Replaced broken link to 542020 with working link to 412060.
Double taxation treaties: Beneficial ownership: Importance of beneficial ownership
amendment do referral info in paragraph 2
Double taxation treaties: Beneficial ownership: Practical consideration of claims
amendment to referral info at paragraph 2
Thin capitalisation: practical guidance: the use of credit ratings: what is a credit rating?
Reissuing as didn't get published.
updated short title
updated title
Diverted Profits Tax: notification, charging and payment: interaction with Corporation Tax penalties
updated final paragraph to include link to CH manual
DT applications and claims - Types of income: Royalties
Page removal as requested by TP Team.
Removal of page per TP Team.
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.
Transfer pricing operational guidance: Accurate delineation of the actual transaction: Risk
amended various typos throughout the page.
Transfer pricing: operational guidance: Evidence gathering: Index page: contents
New page added - INTM485025
New para added at the head of the page
2023
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.
Page amended to provide details on how HMRC reach a general view on foreign entities, including factors considered.
Paragraph added on how list is intended to be used.
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
Transfer pricing records: contents
inserting new page/section
Investment from abroad: Inward Investment Support
Page re-published so the the last link displays on the GOV.UK website as well
Publish manual to add new page INTM120181.
Test to check if publishes correctly to GOV.UK
DT applications and claims - Types of income: Interest
Updated to remove ref to local offices
Transfer pricing records: materiality of a category of controlled transactions
amended 2 typos in Example
UK residents with foreign income or gains: certificates of residence: for trusts
Capitalisation/grammar
Transfer Pricing: methodologies: Mutual Agreement Procedure: HMRC contacts
Update to contact details
New page added
New page added
new page added and moved to correct location in contents
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)
Diverted Profits Tax: customer engagement with HMRC: initial contact between customers and HMRC
updating contact details
updating contacts info
Diverted Profits Tax: appendix A - notification template guidance
updating contact details
Updated contact info
Transfer pricing: operational guidance: working a transfer pricing case: penalties
additional paragraphs added
Thin capitalisation: practical guidance: private equity: private equity buyout funding structures
typo
Thin capitalisation: practical guidance: the use of credit ratings: what is a credit rating?
typo
typo
wording update
typos
Thin capitalisation: practical guidance: private equity: payment-in-kind (“PIK”) notes
typos
typo
wording update
Thin capitalisation: practical guidance: private equity: what is private equity?
typo
re-write
re-write
updating links
re-write
title update
wording update
update wording
re-write
re-write
re-write
re-write
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re-write
re-write
typo
re-write
Thin capitalisation: practical guidance: lending against asset values: offshore property companies
re-write
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
re-write
Thin capitalisation: practical guidance: private equity: payment-in-kind (“PIK”) notes
re-write
re-write
wording update
wording update
wording update
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
wording update
re-write
title alteration
re-write
re-write
Thin capitalisation: practical guidance: the use of credit ratings: in-house credit ratings
re-write
rewrite
Transfer of assets abroad: introduction
Page archived
Transfer of assets abroad: Overview of ITA2007/Sections 721 and 727 (‘Income Charge’)
Page archived
Transfer of assets abroad ('Benefits Charge')
Page archived
Transfer of assets abroad: Overview of ITA2007/S736 - 742 - exemption from liability
Page archived
Transfer of assets abroad: mandatory referral to WMBC Assets, Edinburgh
Page archived
Transfer of assets abroad: checklist of indicators
Page archived
Transfer of assets abroad: what information is needed by WMBC Assets Edinburgh
Page archived
Transfer of assets abroad: Working transfer of assets enquiries with WMBC Edinburgh
Page archived
Thin capitalisation: practical guidance: lending against asset values: offshore property companies
Changed the penultimate paragraph wording slightly and added new link to INTM60000 that has extensive new guidance published in this section
Tweak to the link intm600000
Transfer of assets abroad: contents
Publication of new guidance, replacing what was INTM600010 - INTM600080
2022
New page INTM269079A added
Double Taxation applications and claims: time limit: Notice of intention to claim
Team and mailbox updated to ukmap.individuals@hmrc.gov.uk
reinstated broken links
Diverted Profits Tax: notification, charging and payment: how to notify
fixed broken links
fixed broken link
Immunities and Privileges Overview
Email updated to international.immunitiesprivileges@hmrc.gov.uk
email changed to BAI, Business International (Immunities & Privileges)
email updated to international.immunitiesprivileges@hmrc.gov.uk
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
Transfer pricing: methodologies: Advance Pricing Agreements: monitoring and review
amending link to contact details
Transfer pricing: operational guidance: governance: the resolution stage
update to panel names
Transfer pricing: operational guidance: governance: the Transfer Pricing Group
Updating panel names
updating team/panel names
Transfer pricing: operational guidance: governance: contents
note added for readers
Transfer Pricing: methodologies: Mutual Agreement Procedure: HMRC contacts
change of contact details
The Non-resident Landlords Scheme: Overview of the Scheme
Second Para of ITM370010 deleted
The Non-resident Landlords Scheme: Overview of the Scheme
Spelling error corrected
Thin capitalisation: practical guidance: lending against asset values: offshore property companies
New para inserted to reflect changes post 5 April 2019
change to wording of the last sentence of 5th paragraph
Removed co-op UA in consultation and agreement with CT Structures Team (V Baker)
The Non-resident Landlords Scheme: Overview of the Scheme
Further line added referring to guidance at PIM4820
Distribution exemption: Exemption for small companies: definitions
Table updated
New paragraph added to guidance in relation assessment and closure notices and Commissioners sanction.
Double Taxation applications and claims: time limit: Attempt to claim after expiry of time limit
Mailbox address added for PT team.
Link added to mailbox
DT claims and applications - Types of income: Pensions and Annuities
NHS pension details updated
NHS pension updated
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: recent changes
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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: recent changes
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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: recent changes
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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: recent changes
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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: recent changes
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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
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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: recent changes
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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: recent changes
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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
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Diverted Profits Tax: introduction and overview: recent changes to the legislation
additional bullet added
Diverted Profits Tax: notification, charging and payment: designating the end of the review period
sentence added for clarity
sentences added for clarity
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'
Final two paragraphs on the page removed
Guidance amended
2021
Transfer Pricing: methodologies: Mutual Agreement Procedure: HMRC contacts
contact details changed for Individuals
The Non-resident Landlords Scheme: Compliance
Changes made to wording under non resident landlords section.
Diplomatic Missions: official/other emoluments
Address Updated
Forces of other countries stationed in UK: residence status
wording added to end of first bulet point 'or their dependents or'
Employees of international organisations: claims by individuals
Email updated to international.immunitiesprivileges@hmrc.gov.uk
email changed to international.immunitiesprivileges@hmrc.gov.uk
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
fixed a broken link
Diverted Profits Tax: notification, charging and payment: who issues the notice
Updated link
Diverted Profits Tax: imposing a charge – procedure and governance: overview
broken link fixed
broken link fixed
broken link fixed
Diverted Profits Tax: imposing a charge – procedure and governance: charging notice
broken link fixed
broken link fixed
Interest and Royalty payments - legislation
additional heading added
Additional heading added
What the Interest and Royalty Payments legislation says
additional heading added
Who is affected by the Interest and Royalty Payments Legislation?
additional heading added
What an interest payment exemption notice covers
additional heading added
Procedures for claims on interest payments
additional heading added
Corporation Tax caseworker communication
additional heading added
Handling enquiries into claims on interest payments
additional heading added
Treatment of royalties under the Interest and Royalty Payments Legislation
additional heading added
What happens if a claim is refused or an exemption notice cancelled
additional heading added
EU Interest and Royalties Directive: Anti-avoidance measures
additional heading added
Interest and Royalty payments - overview
change to wording of para 3.
Certificates of Residence Service During the COVID-19 Period
Updated Ireland date
Transfer Pricing: methodologies: Mutual Agreement Procedure: HMRC contacts
updating contact details
Transfer pricing: methodologies: Advance Pricing Agreements: expression of interest
amendments to contact details
amendment to contact details
International financial glossary
update to disclaimer info
update to contact details
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
International organisations: Procedure: how to deal with claims
Email address updated to Immunities & Privileges, International (CS&TD)
Double Taxation applications and claims: Vouchers: Common types of voucher
Hyperlink to table updated
Link to table updated
Transfer of assets abroad: Overview of ITA2007/Sections 721 and 727 (‘Income Charge’)
Reference to SPT Nottingham changed to Trust Compliance, Edinburgh
contact details updated
amendment to contact details
2020
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
Amended email contact as colleague moving from business area
Diverted Profits Tax: imposing a charge – procedure and governance: contents
Re-published to show the entries on the GOV.UK website
Republish to push menus through. No content change
Certificates of Residence Service During the COVID-19 Period
amendment to para on Indonesia
Exchange of information: Introduction to EOI and Requests
Page archived
Exchange of information: General
link removed
Page archived
Exchange of information: Spontaneous exchanges
Page archived
Pages iNMT156010 - 156030 archived
All pages linked archived - link to where guidance is now added
Exchange of information: Automatic exchanges
Page archived
Exchange of information: Use and Disclosure of information received from overseas
Page archived
Exchange of information: Form of report
Page archived
Exchange of information: Notifications to taxpayers on behalf of other EU Member States
Page archived
Transfer Pricing: Operational guidance: contents
adding page to index
Description of double taxation agreements: Mutual agreement procedure
Amendment to page providing link to INTM423110
Transfer Pricing: methodologies: Mutual Agreement Procedure: HMRC contacts
email address updated for individuals CA
Transfer Pricing: methodologies: Mutual Agreement Procedure: HMRC contacts
Shaun Thomas added
hyperlink re-added to page
Offshore Receipts in respect of Intangible Property (ORIP): Process and procedures: Overview
Adding link to courier info on GOV.UK
Offshore Receipts in respect of Intangible Property (ORIP): Glossary of terms: Other definitions
internal hyperlinks added
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
internal hyperlinks added
Offshore Receipts in respect of Intangible Property (ORIP): Exemptions: Limited UK sales
Internal links added
internal hyperlinks added
internal hyperlinks added
internal hyperlinks added
internal links added
internal links added
internal hyperlinks added
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
internal hyperlinks added
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
draft guidance - not yet ready to be published
guidance now live
draft guidance - not yet ready to be published
guidance now live
draft guidance - not yet ready to be published
guidance now live
draft guidance - not yet ready to be published
guidance now live
draft guidance - not yet ready to be published
guidance now live
draft guidance - not yet ready to be published
guidance now live
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
draft guidance - not yet ready to be published
draft guidance - not yet ready to be published
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
draft guidance - not yet ready to be published
draft guidance - not yet ready to be published
draft guidance - not yet ready to be published
draft guidance - not yet ready to be published
draft guidance - not yet ready to be published
draft guidance - not yet ready to be published
draft guidance - not yet ready to be published
draft guidance - not yet ready to be published
draft guidance - not yet ready to be published
draft guidance - not yet ready to be published
draft guidance - not yet ready to be published
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
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
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
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
Offshore Receipts in Respect of Intangible Property: Contents
CHANGE TO SHORT TITLE
Offshore Receipts in respect of Intangible Property (ORIP): Process and procedures: Treaty claims
link to diagram added
Offshore Receipts in Respect of Intangible Property: Contents
Removing text as this is now the main index page for ORIP
slight amendment to page title
Offshore Receipts in respect of Intangible Property (ORIP): Process and procedures: Treaty claims
Image removed
Distribution exemption: Exemption for all other companies: meaning of "ordinary shares"
link to CTM00511 added
Offshore Receipts in Respect of Intangible Property: Contents
adding to index page
Company residence: 'Treaty non-resident' companies
Amended para inserted
DT claims and applications - Types of income: Pensions and Annuities
re-formatting of numbers
Royalty Withholding: UK Source: Interaction with Diverted Profits Tax: Examples
hyperlink to diagram re-added
Royalty Withholding: UK Source: Interaction with Diverted Profits Tax: Examples
diagram removed
Certificates of Residence Service During the COVID-19 Period
text added for switzerland
minor amendment to contents title
Royalty Withholding: Anti Treaty Shopping Rules: Contents
minor amendment to contents title
Royalty Withholding: Definition of a royalty: Contents
minor amendment to short title
Royalty Withholding: UK Source: Contents
minor amendment to short title
Royalty Withholding: UK Source: Interaction with Diverted Profits Tax: Contents
minor amendment to short title
HMRC Approach to Company Residence in response to COVID-19 Pandemic
final two paragraphs added
HMRC Approach to UK Permanent Establishments in response to COVID-19 Pandemic
final paragraph added
remove addresses during covid-19 period
Certificates of Residence Service During the COVID-19 Period
amendment to working time paragraph
Certificates of Residence Service During the COVID-19 Period
paragraph on Taiwan added
HMRC Approach to Company Residence in response to COVID-19 Pandemic
added hyperlink to INTM261010
HMRC Approach to UK Permanent Establishments in response to COVID-19 Pandemic
Added hyperlink to INTM120185
amendment to sub-contents page
Non-residents trading in the UK: introduction: contents
change to contents page
change to contents page
UK residents with foreign income or gains: income arising abroad: Partnerships
Further removal of link to DT Manual
UK residents with foreign income or gains: income arising abroad: Partnerships
reference to DT1750 removed as obsolete.
Exchange of information: Form of report
new template added and paragraph redacted
minor format change
format of letters changed
number format changed
change of contact details
link added to mailbox
Controlled Foreign Companies: Entity Exemptions: contents
Minor spelling error
Transfer of assets abroad: Overview of ITA2007/S736 - 742 - exemption from liability
minor format change
Interest imputation: transfer pricing the lender: implicit and explicit loan guarantees
minor format change to numbers
minor re-formatting of numbers
Transfer pricing: the main thin capitalisation legislation: Treatment of interest when it is paid
minor re-formatting of numbers
minor re-formatting
minor re-formatting
Transfer pricing: Methodologies: OECD Guidelines: Importance of Article 9 of OECD Guidelines
minor re-formatting
minor re-formatting of numbers
Company residence: Statement of Practice 1/90
format changes
UK residents with foreign income or gains: double taxation relief: Basic principles
minor format change to numbers to make then in sequence
UK residents with foreign income or gains: double taxation relief: ICTA88/S794 - exceptions
minor format change from letters to numbers
minor formant change from letters to numbers
UK residents with foreign income or gains: income tax: Limit of credit
format change to numbers
minor format change to numbers
format change
format change
format change
format change
further format changes - numbers reinstated
format change
text change
UK residents with foreign income or gains: certificates of residence: for partnerships
format change
UK residents with foreign income or gains: certificates of residence: for trusts
redact hyperlink
minor format change
minor format change
change to guidance, hyperlink added to PT Ops action guide
update after TTOD case, extra paragraphs added
2019
amendment made on how to contact the APA team
Transfer of assets abroad ('Benefits Charge')
Updated to explain changes under S731 ITA07
contact details amended for Collective Inv. Schemes
Transfer of assets abroad: mandatory referral to WMBC Assets, Edinburgh
links to Trusts Edinburgh amended
links amended
Transfer pricing: operational guidance: working a transfer pricing case: opening the case
hyperlink changed
Transfer pricing: operational guidance: working a transfer pricing case: how many years?
amending text
Transfer pricing: operational guidance: working a transfer pricing case: penalties
hyperlinks updated
hyperlink changed
update link
repeat hyperlink removed
Transfer pricing operational guidance: Accurate delineation of the actual transaction: Full process
update hyerlink
hyperlink changed
HYPERLINKS UPDATED
Procedures for claims on interest payments
Hyperlink changed
Transfer pricing: legislation: rules: exemptions: pre existing dormant companies
MINOR FORMAT CHANGE
Transfer pricing: the main thin capitalisation legislation: Overview
hyperlinks updated
Transfer Pricing: methodologies: Mutual Agreement Procedure: HMRC contacts
email address update
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
broken hyperlink fixed
DT Agreements: Japan - Income from a UK source paid to a resident of Japan
page archived
Page archived
hyperlink changed
typo fixed
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
DT Agreements: Austria - Income from a UK source paid to a resident of Austria
page archived
DT Agreements: South Africa - Income from a UK source paid to a resident of South Africa
page archived
DT Agreements: Switzerland - Income from a UK source paid to a resident of Switzerland
page archived
DT Agreements: Switzerland - Income from a UK source paid to a resident of Switzerland
page archived
Double taxation relief: information and claims: Texts of agreements
MINOR TEXT CHANGE
UK residents with foreign income or gains: double taxation relief: Minimum foreign tax
MINOR TEXT CHANGE
minor text change
MINOR TEXT CHANGE
minor text change
MINOR TEXT CHANGE
Double Taxation Agreements: Spain: Income from a UK source paid to a resident of Spain - Contents
PAGE ARCHIVED
DT Agreements: Switzerland - Income from a UK source paid to a resident of Switzerland
page archived
DT Agreements: Switzerland - Income from a UK source paid to a resident of Switzerland
page archived
DT Agreements: Switzerland - Income from a UK source paid to a resident of Switzerland
page archived
DT Agreements: Switzerland - Income from a UK source paid to a resident of Switzerland
page archived
DT Agreements: Switzerland - Income from a UK source paid to a resident of Switzerland
page archived
DT Agreements: Switzerland - Income from a UK source paid to a resident of Switzerland
page archived
DT Agreements: Switzerland - Income from a UK source paid to a resident of Switzerland
page archived
DT Agreements: Switzerland - Income from a UK source paid to a resident of Switzerland
page archived
DT applications and claims - Types of income: Pensions and Annuities
Hyperlinks changed
DT applications and claims - Types of income: Pensions and Annuities
UPDATE OF TEXT
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: Switzerland - Income from a UK source paid to a resident of Switzerland
page archived
DT Agreements: Switzerland - Income from a UK source paid to a resident of Switzerland
page archived
DT Agreements: Switzerland - Income from a UK source paid to a resident of Switzerland
page archived
DT Agreements: Switzerland - Income from a UK source paid to a resident of Switzerland
page archived
DT Agreements: Switzerland - Income from a UK source paid to a resident of Switzerland
page archived
DT Agreements: Switzerland - Income from a UK source paid to a resident of Switzerland
page archived
DT Agreements: Switzerland - Income from a UK source paid to a resident of Switzerland
page archived
DT Agreements: Switzerland - Income from a UK source paid to a resident of Switzerland
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: 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
Transfer pricing: legislation: rules: Balancing payments
minor update
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: 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
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
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
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
page archived
page archived
page archived
page archived
page archived
page archived
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
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
DT Agreements: Italy - Income from a UK source paid to a resident of Italy
page archived
DT Agreements: Italy - Income from a UK source paid to a resident of Italy
page archived
DT Agreements: Italy - Income from a UK source paid to a resident of Italy
page archived
DT Agreements: Italy - Income from a UK source paid to a resident of Italy
page archived
DT Agreements: Italy - Income from a UK source paid to a resident of Italy
page archived
DT Agreements: Italy - Income from a UK source paid to a resident of Italy
page archived
DT Agreements: Italy - Income from a UK source paid to a resident of Italy
page archived
DT Agreements: Italy - Income from a UK source paid to a resident of Italy
page archived
DT Agreements: Italy - Income from a UK source paid to a resident of Italy
page archived
DT Agreements: Italy - Income from a UK source paid to resident of Italy
page archived
DT Agreements: Italy - Income from a UK source paid to a resident of Italy
page archived
DT Agreements: Italy - Income from a UK source paid to a resident of Italy
page archived
DT Agreements: Italy - Income from a UK source paid to a resident of Italy
page archived
DT Agreements: Italy - Income from a UK source paid to a resident of Italy
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 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
page archived
page archived
page archived
page archived
page archived
page archived
page archived
page archived
DT Agreements: India - Income from a UK source paid to a resident of India
page archived
DT Agreements: India - Income from a UK source paid to a resident of India
page archived
DT Agreements: India - Income from a UK source paid to a resident of India
page archived
DT Agreements: India - Income from a UK source paid to a resident of India
page archived
DT Agreements: India - Income from a UK source paid to a resident of India
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
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: 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
DT Agreements: Iceland - Income from a UK source paid to a resident of Iceland
page archived
DT Agreements: India - Income from a UK source paid to a resident of India
page archived
DT Agreements: India - Income from a UK source paid to a resident of India
page archived
DT Agreements: India - Income from a UK source paid to a resident of India
page archived
DT Agreements: India - Income from a UK source paid to a resident of India
page archived
DT Agreements: India - Income from a UK source paid to a resident of India
page archived
DT Agreements: India - Income from a UK source paid to a resident of India
page archived
DT Agreements: India - Income from a UK source paid to a resident of India
page archived
Transfer Pricing: methodologies: Mutual Agreement Procedure: HMRC contacts
contact details updated
page archived
page archived
page archived
page archived
page archived
page archived
page archived
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
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
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
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
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
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
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
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: 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: 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
page archived
page archived
page archived
page archived
page archived
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
page archived
page archived
page archived
page archived
page archived
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
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
Double Taxation applications and claims - Subject to tax: Examination of claims
removal of hyperlink
Double Taxation applications and claims - Remittance: Examination of claims
removal of hyperlink
DT applications and claims: Overview of DT Agreements
removal of hyperlink
DT Applications and claims: DT Agreements: country A to Z guide
Archiving - reason text added
Page archived
Double Taxation applications and claims: contents
Link to INTM345600 archived
update contact details
update contact details
Double Taxation applications and claims: Vouchers: Block vouchers issued by Irish banks
contact details changed
contact details changed
change of contact details
contact details changed
contact details changed
contact details changed
contact details changed
contact details changed
contact details changed
Double Taxation Applications and Claims: companies: How to tell that a claim is from a company
contact details changed
contact details changed
contact details changed
Double Taxation applications and claims: time limit: Questions about an extension to the time limit
contact details changed
contact details changed
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
contact details changed
UK residents with foreign income or gains: double taxation relief: Statutory income basis
contact details changed
UK residents with foreign income or gains: double taxation relief: Foreign tax
contact details changed
UK residents with foreign income or gains: double taxation relief: Minimum foreign tax
contact details changed
UK residents with foreign income or gains: trusts: Overview
LINK UPDATED
UK residents with foreign income or gains: trusts: Foreign trusts
change to contact details
UK residents with foreign income or gains: trusts: Garland trusts
contact updated
contact details updated
UK residents with foreign income or gains: income tax: Computation - assessable amount
contact details changed
contact details changed
CONTACT DETAILS CHANGED
CONTACT DETAILS CHANGED
CONTACT DETAILS CHANGED
Description of double taxation agreements: Mutual agreement procedure
hyperlink added to page
Double taxation relief: information and claims: To whom claims made
change of contact details
DT applications and claims: Non-resident beneficiaries of UK trusts
re-format of page
Transfer of assets abroad: mandatory referral to WMBC Assets, Edinburgh
email link updated
Transfer of assets abroad: checklist of indicators
email hyperlink updated
hyperlinks added
Introduction: Who do these rules apply to? / How will these rules be used?
hyperlinks added
hyperlinks added
hyperlinks added
Profit Fragmentation Arrangements
hyperlink added
Profit Fragmentation Arrangements: The Material Provision
hyperlink added
Profit Fragmentation Arrangements: Arm’s Length Transfer
hyperlinks added
Enjoyment Conditions: Procurer Test
HYPERLINK ADDED
Exception Conditions: Tax Mismatch
hyperlinks added
Exception Conditions: Tax Mismatch: Quantifying the Resident Party’s Tax Reduction
hyperlink added
hyperlink added
Profit Fragmentation Adjustments
hyperlink added
Profit Fragmentation Adjustments: Hierarchy of Legislation
hyperlinks added
Profit Fragmentation Adjustments: Reimbursement Payments
hyperlink added
hyperlink added
Profit Fragmentation Adjustments
change from draft to published
Profit Fragmentation Adjustments: Reimbursement Payments
change from draft to published
DT applications and claims - Types of income: Interest
Legislation amendment
UK residents with foreign income or gains: double taxation relief: Deduction instead of credit
link update
link updated
Double taxation agreements: residence: Status of diplomats etc
UPDATE LINK
Description of double taxation agreements: Non-discrimination
hyperlink removed
Transfer pricing: Methodologies: OECD Guidelines: Overview
updated paragraph
Transfer pricing: Types of transactions: contents
CHANGE OF ORDER
Transfer Pricing: Types of transactions: difference between accurate delineation and disregard
FORMAT CHANGE
RE-FORMAT
FORMAT CHANGE
FORMAT CHANGE
FORMAT
FORMAT
format
format
format
format change
format change
Double Taxation applications and claims: Vouchers: Common types of voucher
table update
Double Taxation Agreements: Jersey: Income from a UK source paid to a resident of Jersey - Contents
table inserted
DT applications and claims - Provisional Treaty Relief Scheme for Interest
hyperlink fixed
link updated
update link
DT applications and claims - Provisional Treaty Relief Scheme for Interest
link updated
DT applications and claims - Provisional Treaty Relief Scheme for Interest
link fixed
DT applications and claims - Provisional Treaty Relief Scheme for Interest
LINK UPDATED
minor amendment
minor amendment
broken link removed
change email address
slight amendement to contact details
email address amended
International financial glossary
amend email address
amend email address
Arbitrage: legislation and principles: procedures: Clearance procedures
amend email address
amend email
amend email address
amend email address
amend email address
amend email address
Investment from abroad: Inward Investment Support
amend email address
amend email addresses
Transfer pricing: methodologies: Advance Pricing Agreements: expression of interest
amend email addresses
amend email addresses
Double Taxation applications and claims: Vouchers: Common types of voucher
hyperlink added
removal of actual document
MINOR FORMAT CHANGE
Double Taxation applications and claims: Vouchers: Common types of voucher
table format update
2018
Page archived
Link to INTM219350 archived
Company residence: 'Treaty non-resident' companies
major update to page
Company residence: residence under foreign law
Hyperlink change
Hyperlink change
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
link change
link update
change from links to text
text change
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.
Hyperlink change
text change
Double Taxation applications and claims - Introduction: Scope of this guidance
additional section on exchange of information added
Hyperlink update
Hyperlink & text change
Minor text change
Hyperlink & text change
broken link fixed
DT applications and claims: Non-resident beneficiaries of UK trusts
Hyperlink change
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
change team name
Minor heading change
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
Content updated re BEPS updates to OECD guidelines
text change
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
new page - BEPS update on OECD guidelines
Transfer Pricing: Types of transactions: Services: Low Value-Adding Services
BEPS update to OECD guidance
minor formatting
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
...
formatting
formatting
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
Revised short title
format change
Transfer Pricing: methodologies: Mutual Agreement Procedure: Links to other relevant documents
broken link fixed
broken link fixed
broken link fixed
Foreign Permanent Establishments of UK Companies: anti-diversion rule: Chapter 4.
link updated
link updated
links updated
link fixed
Thin capitalisation: practical guidance: measuring debt: Private Finance Initiative (PFI) companies
link fixed
Thin capitalisation: practical guidance: accountancy issues: acceptable GAAP for thin cap purposes
Links fixed
International financial glossary
link fixed
DT applications and claims - Types of income: Interest
broken link fixed
DT applications and claims - Provisional Treaty Relief Scheme for Interest
link fixed
Thin capitalisation: practical guidance: introduction: what is thin capitalisation?
link fixed
Thin capitalisation: practical guidance: introduction: forms of borrowing
link fixed
link fixed
Thin capitalisation: practical guidance: opening a case: other issues and where to look for them
link fixed
Thin capitalisation: practical guidance: interest cover - debt servicing: matters of interest
links fixed
The Non-resident Landlords Scheme: Overview of the Scheme
link fixed
Treatment of royalties under the Interest and Royalty Payments Legislation
link fixed
Transfer pricing: operational guidance: governance: introduction
broken link fixed
link removed
link fixed
UPDATE LINK
link removed
update link
LINK CHANGE
Controlled Foreign Companies: Creditable Tax of a CFC: Introduction
LINK FIXED
Non-residents trading in the UK: permanent establishment: domestic law and treaty law
LINK UPDATES
update link
link updated
link update
Foreign Permanent Establishments of UK Companies: introduction: procedures
LINKS UPDATED
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
REVISED LINKS
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
update links
LINK UPDATE
LINK UPDATE
Format change
UK residents with foreign income or gains: double taxation relief: Deduction for taxes
LINK UPDATES
Link fixed
link changes
link change
change link
Link updates
UK residents with foreign income or gains: certificates of residence: for trusts
LINK UPDATE
link fixed
LINK UPDATES
minor amendment
link updated
UK residents with foreign income or gains: income arising abroad: Accrued income
LINK UPDATE
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
Investment from abroad: Inward Investment Support
Address change
format change
Description of double taxation agreements: Mutual agreement procedure
Address change
Foreign Permanent Establishments of UK Companies: introduction: procedures
Address change
Transfer pricing: methodologies: Advance Pricing Agreements: expression of interest
address change
formatting
Exchange of information: Use and Disclosure of information received from overseas
ADDRESS CHANGE
format change
Address change
Exchange of information: Introduction to EOI and Requests
address change
Foreign tax paid on trade income: limitations on credit: 2009 legislation
Address change
format
format change
Address change
format change
Address change
Format change
Address change
format change
Address change
aDDRESS CHANGE
Arbitrage: legislation and principles: procedures: Clearance procedures
address change
format change
Address change
Address change
Company residence: standard treaty tie-breakers
Change to title
Company residence: treaty tie-breakers and self-assessment
slight amendment
Company residence: standard treaty tie-breakers
title change
format change
minor change
minor change
short title change
Short title change
Short title change
Short title change
short title change
short title change
short title
LINK CHANGE
Adding pages to contents page
Republish to push through changes.
Adding a page to contents
minor text change
Format change
format change
contents page added
Change to contents page
order change
text change
text change
Double taxation treaties: Beneficial ownership: Importance of beneficial ownership
text change
text change
What the Interest and Royalty Payments legislation says
text change
Updated Diagram
Non-residents trading in the UK: place of contract may not be decisive
text change
Company residence: 'Treaty non-resident' companies
text change
Controlled Foreign Companies: definitions
text change
Minor text change
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
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
text change
Non-residents trading in the UK: introduction
text change
text change
Text change
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
text change
minor change
text change
Update broken link
text change
text change
hyperlink change
hyperlink change
hyperlink change
text change
update links
text change
text change
format change
Links to diagrams updated
text change
Example 1 updated and diagram added
Additional explanation and link to updated diagram.
Explanation and link to updated diagram added to page.
Updated explanations and diagrams added to page
text change
text change
text change
page republished
Page republished
Page republished
added new pages to sub-index
INTM219370 and INTM219380 added to menu
various text changes
minor text change
Diagrams updated
Diagram updated
Diagrams updated
Diagram updated
Diagram updated
Diagram updated
Controlled Foreign Companies: Relevant Interests in a CFC: Other Relevant Interests
Diagram updated
Added link to diagram
Added link to diagram
text change
text change
text change
text change
Update index
Minor change
minor text change
minor text change
text change
text change
Text change
format change
format change
format change
Foreign Permanent Establishments of UK Companies: introduction: procedures
Address change
Transfer pricing: methodologies: Advance Pricing Agreements: expression of interest
Address change
Address change
Exchange of information: Introduction to EOI and Requests
address change
minor text change
Double Taxation applications and claims: Repayment claims from non-residents: The key features
text change
DT applications and claims: manufactured payments
text change
text change
minor text change
Thin capitalisation: practical guidance: introduction: referrals to Business, Assets & International
minor text change
text change
UK residents with foreign income or gains: dividends: Unilateral relief - banks
minor text change
text change
UK residents with foreign income or gains: dividends: Dividend stripping
text change
text change
UK residents with foreign income or gains: dividends: Tax deducted
text change
minor text change
UK residents with foreign income or gains: dividends: Underlying tax - dividend resolutions
text change
UK residents with foreign income or gains: dividends: Foreign dividends - glossary
text change
UK residents with foreign income or gains: dividends: Underlying tax
text change
UK residents with foreign income or gains: dividends: Underlying tax - minimising foreign tax paid
minor text change
UK residents with foreign income or gains: certificates of residence: for trusts
external link added and guidance updated to reflect a policy change
UK residents with foreign income or gains: certificates of residence: for partnerships
external links added
change from hyperlinks to text
Change from hyperlinks to text
Format change
Changing hyperlinks to actual text
hyperlinks changed to text
Change links to text.
format change
change from links to text
change links to text
format change
change links to text
format change
removed links and used text examples
format change
Transfer Pricing: methodologies: Mutual Agreement Procedure: HMRC contacts
amend email links
email link
Non-residents trading in the UK: domestic law permanent establishment/branch or agency
Minor change
Change in team name
Change in contact name
Change of team name
Change in team name
Minor name change
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
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
Address change
Address change
Address change
Investment from abroad: Inward Investment Support
Address change
Address change
Address change
Address change
Address change
Address change
Arbitrage: legislation and principles: procedures: Clearance procedures
Address change
Address change
Address change
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
updated INTM480550
updated intm480540
updated hyperlink
..
Transfer Pricing: methodologies: Mutual Agreement Procedures: Information requirements
correct heading on content
UK residents with foreign income or gains: certificates of residence: for partnerships
paragraphs added
minor para change
Company residence: 'Treaty non-resident' companies
table removed
Transfer Pricing: methodologies: Mutual Agreement Procedure: Links to other relevant documents
change from upper case to lower case on title
Transfer Pricing: methodologies: Mutual Agreement Procedures: Information requirements
change from upper case to lower case on title
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
Thin capitalisation: practical guidance: introduction: referrals to Business, Assets & International
change of team name
change of team name
change of team name
change of team name
change in team name
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
change of team name
change of team name
Change of team name
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
change in team name
Transfer pricing: Operational guidance: alternatives to consider before transfer pricing
change team name
change of team name
Transfer Pricing: Transactions and Structures: business structures: valuable intangibles
change team name
change team name
change team name
Transfer pricing: the main thin capitalisation legislation: Introduction
change team name
change team name
change of team name
change of team name
change of team name
change of team name
change of team name
change of team name
Thin capitalisation: practical guidance: the use of credit ratings: in-house credit ratings
change of team name
change of team name
change of team name
Transfer pricing: legislation: rules: exemptions: small and medium sized enterprises
change of team name
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
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
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
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
change of team name
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.
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.
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.
change of team name
change of team name
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
change of team name
Controlled Foreign Companies: Reviews: Working individual companies
change of team name
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
change of team name
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
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
change from CTIAA to CSTD
Transfer Pricing: Transactions and Structures: business structures: valuable intangibles
change from CTIAA to CSTD
Change from CTIAA to CSTD
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
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
change from CTIAA to CSTD
Double taxation agreements: introduction: OECD and UN model agreements
change from CTIAA to CSTD
change from CTIAA to CSTD
Foreign tax paid on trade income: limitation on credit: 1998 legislation - detail
change from CTIAA to CSTD
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
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
change from CTISA to CSTD
Transfer pricing: Types of transactions: charities
change from CTIAA to CSTD
change from CTIAA to CSTD
change from CTIAA to CSTD
Exchange of information: Spontaneous exchanges
change from CTIAA to CSTD
change from CTIAA to CSTD
change from CTIAA to CSTD
UK residents with foreign income or gains: dividends: Underlying tax
Change from CTIAA to CSTD
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
change from CTIAA to CSTD
change from CTIAA to CSTD
Exchange of information: Use and Disclosure of information received from overseas
change from CTIAA to CSTD
change from CTIAA to CSTD
change from CTIAA to CSTD
Company residence: standard treaty tie-breakers
change from CTIAA to CSTD
Company residence: when to make a submission to BAI
Change from CTIAA to BAI
Minor title change
Change from CTIAA to BAI
Change from CTIAA to BAI
Double taxation agreements: residence: Status of diplomats etc
Change from CTIAA to CSTD
Investment from abroad: Inward Investment Support
Change from CTIAA to CSTD
Change from CTIAA to CSTD
Change from CTIAA to CSTD
Change from CTIAA to CSTD
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
Page archived
Change CRM to CCM
Change CRM to CCM
Transfer pricing: methodologies: Advance Pricing Agreements: monitoring and review
Change from CRM to CCM
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
Change from CRM to CCM
Cash pooling: risk assessment/compliance checks
Change from CRM to CCM
Change CRM to CCM
International movements of capital: Exclusions: cash pooling arrangements
Change from CRM to CCM
Change from CRM to CCM
Change from CRM to CCM
DT applications and claims: Crown Immunity, Sovereign Immunity and Diplomatic Privilege: Contents
Page archived
Page archived
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International Manual: recent changes
Change from CRM to CCM
International movements of capital: Reporting requirement: where should reports be sent?
Changing CRM to CCM
Change CRM to CCM
Change from CRM to CCM
Change from CRM to CCM
Transfer pricing: operational guidance: governance: the selection stage
Change CRM to CCM
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
Change from CRM to CCM
Change from CRM to CCM
Foreign Permanent Establishments of UK Companies: introduction: election for S18A to take effect
Change from CRM to CCM
Change from CRM to CCM
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
Change from CRM to CCM
Change from CRM to CCM
Immunities and Privileges: Contents
New section for International Manual
2017
minor change
minor title change
title change
minor title change
minor title change
minor change
minor change
title change
Address change
Address change
DT claims and applications - Types of income: Pensions and Annuities
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DT claims and applications - Types of income: Pensions and Annuities
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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.
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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
Non-residents trading in the UK: permanent establishment: domestic and treaty law: Contents
Page title changed as part of update to manual
Non-residents trading in the UK: contents
content pages amended
Company residence: 'Treaty non-resident' companies
Hyperlink changes
UK residents with foreign income or gains: corporation tax: Intangible fixed assets
Hyperlink changes
UK residents with foreign income or gains: capital gains tax: Remittance basis
Hyperlink change
Hyperlink change
Transfer of assets abroad: Working transfer of assets enquiries with WMBC Edinburgh
Hyperlink change
Distribution exemption: Interpretation: certain non-dividend distributions
Hyperlink change
Exchange of information: General
Hyperlink changes
UK residents with foreign income or gains: income arising abroad: Accrued income
Hyperlink change
UK residents with foreign income or gains: income arising abroad: Partnerships
Hyperlink changes
UK residents with foreign income or gains: income arising abroad: Employment - double taxation
Hyperlink change
UK residents with foreign income or gains: dividends: EC Directive
Hyperlink change
Hyperlink change
Hyperlink change
Hyperlink change
UK residents with foreign income or gains: corporation tax: Loan relationships
Hyperlink change
UK residents with foreign income or gains: corporation tax: Loan relationships
Hyperlink change
UK residents with foreign income or gains: corporation tax: Dividends: withholding tax
Hyperlink change
Hyperlink change
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
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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.
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
List formatting changed. No chnage to text
updating flow chart link
Transfer pricing operational guidance: Accurate delineation of the actual transaction: Full process
update to diagram link
update to diagram link
Transfer pricing: methodologies: Advance Pricing Agreements: Sample agreement
SP02/10- Advance Pricing Agreements Annex 2 – Sample Agreement update .
to correct numbering
to fix numbering
updated annex 1
Transfer pricing: methodologies: Advance Pricing Agreements: introduction
updated INTM422010
Transfer pricing: methodologies: Advance Pricing Agreements: what is an APA?
INTM422020 updated
UPDATE TITLE
update page numbering
Transfer pricing: methodologies: Advance Pricing Agreements: types of agreement
INTM422030 UPDATED
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
exchange of information seciton added
exchange of information section added
Cash pooling: setting interest rates for participants on an arm's length basis
update new link
Cash pooling: short term and long term balances held in the cash pool
update new links
Cash pooling: UK company as long-term borrower in the cash pool
update link SAIM9075
Intra-group funding: Cash Pooling: contents
republish page to reflect in dir gov site
Arbitrage: legislation and principles: procedures: Clearance procedures
additional sectoin added on exchang of information.
additional section on Exchange of Information added
Interest and Royalty payments - overview
additional section on Exchange of Information added
new pages added
Adding a content page
Intra-group funding: Cash Pooling: contents
new pages added to INTM
amendment to first heading
Controlled Foreign Companies: How the corporate tax regime works for CFCs: Clearances: General
New section on Exchange of Information added at the end of the body text
Cash pooling: Legal and commercial arrangements
update new link
Foreign Permanent Establishments of UK Companies: introduction: procedures
new paras added relating to exchange of information
Cash pooling: short term and long term balances held in the cash pool
updated link
Cash pooling: setting interest rates for participants on an arm's length basis
link updated
Transfer pricing: Operational guidance: alternatives to consider before transfer pricing
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no change to text. just needed to publish as it had reverted to draft
Transfer pricing: Operational guidance: alternatives to consider before transfer pricing
update to link in the 3rd para
remove INTM269079 on 19/01/2017
PAGE WITHDRAWN 19/01/17
INTM269079 WITHDRAWN ON 19/01/17
INTM269079 removed / no longer valid from 19/01/17
Double Taxation applications and claims: DT forms: Introduction
Updating links to forms
INTM269130 amendment
INTM269190 amendment
INTM269200 amendment
INTM269200 amendment
Amendments to INTM269020
Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment manager exemption: the legislation
Overview.
INTM269070 AMENDMENT
INTM269072 AMENDMENT
INTM269074 AMENDMENT
INTM269076 AMENDMENTS
INTM269080 AMENDMENT
Transfer Pricing: Operational guidance: giving transfer pricing advice to customers
amendment to INTM480530
amendment to INTM480540
AMENDMENTS TO INTM480550
2016
Non-residents trading in the UK: domestic law permanent establishment/branch or agency
alteration to reference.
Transfer pricing: legislation: rules: exemptions: SME definition
update to EU website link
Transfer pricing: operational guidance: Evidence gathering: Index page: contents
BEPS updates to OECD guidelines
4 new pages - BEPS updates on OECD guidelines
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
content updated re BEPS updates to OECD guidelines
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
content updated re BEPS updates to OECD guidelines
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
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