tool: Step 2 - Any transactions?
Are there any transactions between the UK taxpayer you
are considering and its
Click the answer: YES
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'
comments on this page and elsewhere on this website are of a
general nature. It is not practicable in a general review such as
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
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.
TPS nor its affiliates
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.