On-line
tool: Step 3 - Members of the group
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.
|