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Solutions Limited 2004-7
On-line tool: Step 3 - Turnover threshold

Does the UK taxpayer's group have turnover exceeding EUR 10 million?

Click the answer:     EXCEEDING     NOT

Guidance to help you determine the answer:

Stage 3 of Step 3 is to apply the thresholds set in the EC Recommendation.  The second threshold relates to turnover (net of VAT).

The threshold is expressed in Euros.  Conversion to sterling is required to be done at average exchange rates over the period of account.  At exchange rates in Spring 2004, EUR 10 million is approximately £7 million. 

These thresholds are applied on a current year, annual basis.  This raises the practical difficulty that enterprises which experience an unexpected surge in turnover close to the year-end could be tipped into the regime for the whole year, at a stage when it may be too late to correct any transfer prices for transactions earlier in the year if they do not meet the arm’s length test. 

A sudden strengthening of the £ versus the Euro could presumably have the same effect.

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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