On-line
tool: Step 3 - Partner
enterprises
Two enterprises are
partner enterprises if there is insufficient
control to be linked enterprises, but one of them holds, either solely
or jointly with one or more linked enterprises, 25% or more of the
capital or voting rights of another enterprise.
The reason for distinguishing from linked enterprises is that less than
100% of the partner enterprise's data is used. Aggregation is in
proportion to the percentage interest in the capital or voting rights
(whichever is the greater).
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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