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Solutions Limited 2004-7
Links to information about transfer pricing

OECD

The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations set out the consensus on how the arm's length test should be applied.  They are broadly accepted by all OECD member countries, and many others.

The OECD Commentary on the Model Tax Convention sets out the equivalent consensus on the application of double tax treaties.

Both documents are the foundations for any transfer pricing work, and can be bought here and here, respectively.

The OECD's transfer pricing homepage is here.  This has many documents for download, including the discussion draft regarding the proposed changes to the calculation of the profits of a branch (PE).

Inland Revenue

IR's new transfer pricing webpage, containing (among other things) copies of their draft guidance notes, is here.

The IR's International tax Handbook is here.
The IR's International manual (written for use by Inspectors of Tax), which includes guidance on the application of the UK transfer pricing rules, is here.

The UK legislation on transfer pricing prior to 1 April 2004 is here.
The discussion draft on the proposed new legislation, which will apply from 1 April 2004, is here. (Click on the document called CT Reform: The Next Steps: IR Technical Note (PDF 1,158K)).

IR Tax Bulletins providing guidance (with which, incidentally, TPSL does not always agree) on:
  • their transfer pricing record-keeping requirements here.
  • how penalties apply to transfer pricing in the UK here.
  • their new procedures to make transfer pricing enforcement more efficient: here.
  • intra-group payments of interest here and here.  (Note: some of this is now obsolescent.)
  • the EU Arbitration Convention here.
  • transfer pricing consequences of share option schemes here.
Statement of practice on Advance Pricing Agreements (APAs) here.

Code of practice 10 ("COP10"), under which rulings may be available on some transactions here.

Copies of all the UK's Double Tax Treaties are here and other IR information on the Treaties is here.
Other

Copy of the ECJ's judgement in the Lankhorst anti-discrimination case, which is the primary catalyst for the new UK transfer pricing rules: here.

Copy of the IRS's proposals for new rules on treatment of intra-group services: here.

















The 'small print'

The comments on this page and elsewhere on this website are of a general nature.  It is not practicable in a general review such as this to consider every convolution of the UK transfer pricing rules or of any other tax law that may be relevant.  Moreover, these pages naturally do not take into account the specific facts relating to any particular taxpayer.  Therefore, although the guidance in this website should give a good indication of the likely position under the transfer pricing rules, taxpayers should obtain professional advice to verify the position, or carry out their own analysis.

Neither TPS nor its affiliates and employees make any representation regarding the completeness or accuracy thereof and they accept no responsibility for any loss or damage incurred as a result of any user acting or refraining from acting upon anything contained on these pages or upon its omission therefrom.