HMRC has rewritten the transfer pricing guidance in its International Manual.
‘We’ve made this change for two reasons,’ HMRC said. ‘First, we wanted to update the guidance and ensure that it gives a consistent message. And secondly we felt the guidance could be made easier to use. The improvements we have made include reworking the structure so that information is presented in a more logical way, and we’ve increased the use of hyperlinks to make it easier to cross reference other subjects in the manual.’
The old guidance at INTM430000 has been withdrawn and replaced by new pages starting at INTM410000. The structure of the revised guidance – on legislation, methodologies, transactions and [business] structures, operational matters and thin capitalisation – is set out at INTM410510.
A destination table is provided at INTM489030.
HMRC has rewritten the transfer pricing guidance in its International Manual.
‘We’ve made this change for two reasons,’ HMRC said. ‘First, we wanted to update the guidance and ensure that it gives a consistent message. And secondly we felt the guidance could be made easier to use. The improvements we have made include reworking the structure so that information is presented in a more logical way, and we’ve increased the use of hyperlinks to make it easier to cross reference other subjects in the manual.’
The old guidance at INTM430000 has been withdrawn and replaced by new pages starting at INTM410000. The structure of the revised guidance – on legislation, methodologies, transactions and [business] structures, operational matters and thin capitalisation – is set out at INTM410510.
A destination table is provided at INTM489030.