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Solutions Limited 2004-7
On-line tool: Step 1 - Taxpayer is not a body corporate or a partnership

The transfer pricing rules are primarily seen as applying to companies and partnerships, but it is worth noting that the rules can apply to any other legal “person”, such as individuals and trusts.  However, such persons are only caught if they control a company or partnership (not vice-versa). 

So, for instance, 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). 

This means that certain entrepreneurs who own companies might (unless they are excluded by steps 2-5) have to review their interactions with the companies they control, for instance the salary they are paid.  This might include some surprising people, such as 'megastar' pop stars, who tend to supply their services via personal services companies.

The rules do not apply to transactions between, for instance, a husband and wife, or an individual and a trust. 

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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