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On-line tool: Step 2 - Any transactions?

Are there any transactions between the UK taxpayer you are considering and its related parties?

Click the answer:     YES     NO

Guidance to help you determine the answer:

The transfer pricing rules apply to transactions with related parties, so if there are none then the transfer pricing rules cannot apply.  It will usually be obvious whether there is a transaction.

However, it is important to appreciate that the rules have deliberately been worded as widely as possible, to ensure that almost any interaction is caught.  (Indeed, partly for this reason the actual legislation uses the term "provision", rather than "transaction".  As "provision" is ambiguous, we prefer "transaction".)

For more explanation of how to make sure you have not overlooked a transaction, click here.

Another point to watch is that indirect transactions can also be caught.  There could still be a "transaction", even in the absence of what most businessmen or women would recognise as a transaction.  More 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.
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