tool: Step 4 - Employee threshold
Does the UK taxpayer's group employ fewer than 250
Click the answer: FEWER
Guidance to help you
determine the answer:
employees or new-hires and departures during the year count as
fractions of an employee. Staff headcount includes owner-managers
and partners, but not apprentices and certain students.
These thresholds are applied on a current year, annual basis.
This raises the practical difficulty that enterprises which experience
an unexpected surge in staff numbers, 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
The 'small print'
comments on this page and elsewhere on this website are of a
general nature. It is not practicable in a general review such as
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
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.
TPS nor its affiliates
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.