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UK Domestic Transfer Pricing

Paul Fay Director in Horwath Clark Whitehill's London Corporate Tax Group considers the Revenue guidance on the application of the new UK domestic transfer pricing regime
Transfer pricing rules require broadly arm's-length terms to be used for tax purposes in transactions between connected companies. Up to 31 March 2004 this normally only applied for cross-border group transactions. Subject to the Finance Bill passing from 1 April 2004 the transfer pricing regime is extended to cover transactions between connected UK companies.
This will impose major new compliance burdens on many businesses and in response the Revenue has published guidance on a number of aspects of the new rules. Some of the key issues for UK domestic transactions are discussed below.

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