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Business creation investment

Certain investors cannot be partner enterprises.  These include:
  • venture capitalists
  • universities and non-profit research centres
  • small local authorities
  • institutional investors, including regional development funds
However, this exclusion extends to linked enterprises to only a very limited extent (see Annex C).  In most cases, where such investors control a particular UK taxpayer, the investor must be included in the taxpayer's group in assessing whether the taxpayer is "small".

Back to groups.

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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