tool: Step 3 - Small enterprise exemption
In order to avoid disproportionate compliance
costs for smaller companies, there is an exemption
from the UK transfer
pricing rules for small-sized enterprises. There is
also an exemption for medium-sized enterprises, but
this is not as beneficial, so it make sense to
consider the small-sized exemption first.
There are three stages to applying this exemption:
Stage 1 - The group
- Determine the taxpayer's "group".
- Check that the small enterprise exemption
the transaction you are looking at.
- Check whether the taxpayer is below the
The exemption would more aptly have been named the small group
exemption, because whether a taxpayer is
"small" is not measured
reference to the attributes of the taxpayer on a
basis. Rather, it is necessary to amalgamate
the taxpayer with
other associated entities. Let's refer to
these companies as the
So, first of all you need to work out which entities
are to be included
in the group.
to do so.
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
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.