Transfer Pricing
Resources for Great Britain
Government Links
UK Transfer
Pricing Regulations
HMRC Tax
Bulletins on Transfer Pricing
News and Other Resources
Government Links
Her Majesty's
Revenue and Customs (HMRC) Homepage
HMRC's International Transfer Pricing Page
HMRC's Transfer Pricing and Corporation Tax Self Assessment Page
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UK Transfer Pricing
Regulations
1998 Finance Act
Section 108 introduces a comprehensive modernization of the
UK’s transfer pricing legislation.
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HMRC Tax Bulletins on
Transfer Pricing
Transfer Pricing and the Arbitration Convention
The Convention provides for independent arbitration to ensure
the elimination of double taxation by EU Member States which could arise
from a transfer pricing adjustment made by a Member State. Guidance about
how the Convention works was provided in
Tax Bulletin, Issue 31, October 1997.
Released August 1998
Transfer Pricing Legislation
The 1998 Finance Act (FA 98) introduced a comprehensive
modernization of the UK’s transfer pricing legislation. Under the transfer
pricing legislation, taxpayers are required to recognize the arm’s length
principle in reporting income, profits or losses for tax purposes.
Released October 1998
Penalties and the Transfer Pricing Legislation
Bulletin details penalties under the UK's transfer pricing
legislation.
Released December 1998
Advance Pricing Agreements
This guidance about the procedures relating to bilateral
Advance Pricing Agreements draws on the experiences and observations of the
Inland Revenue in concluding APAs with its treaty partners under the
authority of the Mutual Agreement Procedure of Double Tax Treaties.
Released October 1999
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News and Other Resources
Reform of
Loan Rules for Connected Companies
The HMRC is to introduce corporate tax legislation that
amends the loan relationships rules affecting connected companies. The new
rules will apply to the release of trade debts owed between connected
companies. The change will also amend the rules on the late payment of
interest between connected companies.
November 24, 2008
House of Commons
Committee of Public Accounts – Management of Large Business Corporation Tax
– Thirtieth Report of Session 2007-08
This report discusses the latest actions taken to contest
apparent tax avoidance, which includes legislation to force disclosure of
tax avoidance plans, application of transfer pricing rules to cross-border
intangible transfers, the introduction of the risk-based approach, and use
of the tax penalty regime.
October 21, 2008
HMRC Issues Updated Guidance Regarding the Conduct of Transfer Pricing
Enquiries
This guidance outlines the practices and procedures HMRC has
adopted for transfer pricing enquiries in order to achieve the aims of
Proposal 5 of the 2006 Review of Links with Large Business. These were
greater certainty; an efficient risk based approach to dealing with tax
matters; speedy resolution of issues; and clarity through effective
consultation and dialogue.
June 10, 2008
Draft Statutory Instrument, The Transfer of Tribunal Functions and Revenue
and Customs Appeals Order 2008
The UK is creating a new tribunal to hear taxpayer appeals
from HMRC notices of inquiry, including those in transfer pricing cases.
Such appeals were previously heard by the Special Commissioners.
June 2, 2008
Risk Framework Guidance
Provides guidance for large businesses to pay the right
amount of tax at the right time and how to manage tax risk to ensure
compliance with the law. HMRC’s aim is to work with its customers to
understand how they manage their tax planning and compliance within the
wider commercial context in which they operate. It does not want its
interventions to duplicate unnecessarily the work that tax departments and
their advisers do to manage tax compliance risks.
December 2007
HMRC
Approach to Transfer Pricing Enquiries
The HMRC announced the appointment of
transfer pricing specialists and the provision of additional training aimed
at enhancing their specialist skills, as part of the introduction of the new
approach to transfer pricing enquiries. A new HMRC internal governance
process, effective January 2008, addresses issues concerning consistency of
approach, allocation of resource to risk, and broader strategic objectives.
October 2007
HMRC Approach to Transfer Pricing for Large Businesses
This consultation document seeks views on a new approach to
the administration of transfer pricing enquiries for large business. HMRC
welcomes views on these proposals which take forward the key themes of
giving increased and earlier certainty to business, moving closer to
real-time working and speedier resolution of issues.
June 20, 2007
Changes to Clearance Processes for Financial Transactions
The UK proposed extending its advanced pricing agreement
program to settle possible thin capitalization concerns, announcing that
unilateral “advance thin capitalization agreements” would allow taxpayers to
achieve assurances without having to seek out relief through double taxation
treaties.
May 7, 2007
UK/Japan Double Taxation Convention
Signed February 2, 2006, Entered into force October 12, 2006
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