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On-line tool: Step 3 - Linked enterprises

To the data from the accounts of the taxpayer (or its consolidated group) must be added 100% of the data for any "linked enterprises', to the extent that they have not already been included.

For the full definition of linked enterprises, see the EC Recommendation. However, the test boils down to tracing control up and down the chain. This is not quite the same as the concept of control discussed in Step 1 (that would be too easy, wouldn't it?), but it is similar.

Most linked enterprises will already be in the consolidated accounts of the ultimate parent company, but one obvious potential addition is the data of any majority shareholder that is not a body corporate.

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.

On-line tool: navigation

Introduction

Step 1

Step 2

Step 3

Step 4

Step 5