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Solutions Limited 2004-7
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).

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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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Introduction

Step 1

Step 2

Step 3

Step 4

Step 5