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Text © Transfer Pricing
Solutions Limited 2004-7
On-line tool: Step 1 - Taxpayer is a company

If the taxpayer is a company, then you need to know what kind of entity the potentially-related party is.

If the other party is a company

Company A is related to Company B if A controls B, or B controls A, or A and B are under common control (by another company or other person/s). 

If the other party is a partnership

Company A is related to partnership B if A controls B, or B controls A, or A and B are under common control (by any other person/s).

If the other party is any other person

A company and any other person (such as an individual or trust) are related to one another if the latter controls the former (but not vice-versa). 

The transfer pricing rules are primarily seen as applying to companies and partnerships, but it is worth noting that the rules can apply to other legal “persons”, such as individuals and trusts, if they control a company or partnership. 

This means, for instance, that if an individual owns a company, the transfer pricing rules potentially apply to the individual as well as the company (in relation to transactions between them). 

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.
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