The UK transfer pricing environment is one of the most advanced in the world and in 2010 it continued to progress with significant developments including:
Legislation and guidance
A rewritten version of the UK transfer pricing legislation became effective on 1 April 2010. The legislation is now contained within Part 4 of the Tax (International and Other Provisions) Act 2010 although the core principles remain unchanged.
HMRC issued in March 2010 a major rewrite of their international tax manual regarding thin capitalisation. The key developments are: expanded guidance on Credit Ratings with a clear acknowledgement that ratings models can be a useful way of pricing loans and expanded material on the various ratios which can be used in evaluating thin capitalisation issues and when each ratio is appropriate. However the Manual makes clear that HMRC does not operate safe harbours; and
a new section covering thin capitalisation...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
The UK transfer pricing environment is one of the most advanced in the world and in 2010 it continued to progress with significant developments including:
Legislation and guidance
A rewritten version of the UK transfer pricing legislation became effective on 1 April 2010. The legislation is now contained within Part 4 of the Tax (International and Other Provisions) Act 2010 although the core principles remain unchanged.
HMRC issued in March 2010 a major rewrite of their international tax manual regarding thin capitalisation. The key developments are: expanded guidance on Credit Ratings with a clear acknowledgement that ratings models can be a useful way of pricing loans and expanded material on the various ratios which can be used in evaluating thin capitalisation issues and when each ratio is appropriate. However the Manual makes clear that HMRC does not operate safe harbours; and
a new section covering thin capitalisation...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
