Transfer pricing
Actual provision, meaning
Adjustments
Generally
Interest
Royalties
Advance pricing agreements
Generally
Affected persons, meaning
Alternative finance arrangements
Appeals
Appeals versus mutual agreement procedure
Arbitration convention
Arm's length principle, OECD guidelines
Actual transactions undertaken, recognition of
Application of arm's length principle
Appropriate method, selection of
Business restructurings
Comparability analysis
Comparable uncontrolled price method
Cost contribution arrangements
Cost plus method
Customs valuations, use of
Evaluation of separate and combined transactions
Generally
Government policies, effect of
Intangible property
Intra-group services
Losses
Profit split method
Resale price method
Transactional net margin method
Arm's length provision
Meaning
Securities
Security issued and guarantee given
Thin capitalisation
Arm's length provision, meaning
Associated enterprises
Attribution of profits
Balancing payments
Capital market condition, meaning
Election to pay tax, disadvantaged persons
Election to pay tax, guarantee cases
Generally
Payments not to be taken into account, disadvantaged persons
Payments not to be taken into account, guarantor to issuer
Basic rule
Application
Calculations to be based on arm's length principle
Dormant companies pre-1 April 2004, exemption for
Exemption from
Generally
Participation condition
Small and medium-sized enterprises, exemption for
Capital allowances
Captive insurance company insuring extended warranties for customers
Case study
Changes in trading stock
Chargeable gains
Claims by disadvantaged persons
Arm's length calculation, return must have been made
Claim not allowed
Controlled foreign company, compensating payment
Double taxation relief
Extending claim period
Generally
Indirect participation, issue of security with guarantee
Interest exceeding arm's length interest
Notice to potential claimants
Relevant notice, meaning
Return, meaning
Securities issued between companies, alternative way of claiming
Time for making/amending
Transfers of trading stock
Comparability data and developing countries
Compensating adjustments
Charge to income tax, disadvantage person
Claims
Controlled foreign companies, applicable rule
Double taxation relief restriction
General rule
Generally
Guarantees
Security, provision relating to
Trading stock, applicable rule
Control, meaning
Decommissioning expenditure
Derivative contracts
Determinations
Determinations requiring commissioners' sanction
Appeals, restriction of right to
Application of rules
Exemption from requirement
Generally
Development of UK provisions
Direct and indirect participation, meaning
40 per cent test
Application
Example of
Generally
One of a number of major participants
Persons acting together to provide financing arrangements to both affected persons
Persons acting together to provide financing arrangements to one affected person
Potential for direct participation
Direct participation in management/control or capital of person
Disclosure of information, offences
Diverted profits tax
Compliance and administration
Generally
Documentation
Country-by-country reporting
Existing rules
Dormant companies, exemptions from basic rule
Double taxation
Compensating adjustments
EU Arbitration Convention
Mutual agreement procedure
Double taxation elimination
Dutch treaty (as example)
Election to pay tax of advantaged person, securitisation
Enquiries
EU Arbitration Convention
EU Code of Conduct
EU Joint Transfer Pricing Forum
European law and
Exemptions from basic rule
Dormant companies
Exceptions
Non-qualifying territory, meaning
Qualifying territory, meaning
Small and medium-sized enterprises
Transfer pricing notices
Firm, meaning
Generally
Guarantor, deduction of interest paid under a security
Generally
Interaction between claims
Treatment as issuing company on making claim
Who can make claims
History
Income profits and capital gains
Indirect participation in management/control or capital of person
Connected, meaning
Financing arrangements
Generally
One of several major participants
Potential direct participant
Interest paid
International developments
Involvement of entities or transactions lacking economic substance
Loan relationships
Losses, meaning
Non-UK company avoiding UK taxable presence
OECD principles
Oil and gas sales
Oil-related ring-fence trades
Generally
Meaning
Open assessments, adjustments
Penalties
Position of purchaser
Potential advantage, meaning
Profits, meaning
Provisions not at arm's length
Commencement
Documentation, temporary relaxation of liability to penalties
Enquiry, notice of
Penalties, temporary relaxation of liability
Thin capitalisation
Tonnage tax
Transitional provisions
Record keeping
Relevant activities
Restrictions re borrowing costs
Royalties
Scope of TIOPA 2010, Pt. 4
Securitisation
Self-assessment obligations
Series of transactions, meaning
Sharkey v Wernher principle
Small and medium-sized enterprises
Exception to exemption from basic rule
Exemptions from basic rule
Medium-sized enterprise, meaning
Small enterprise, meaning
Transfer pricing notices
Small and medium-sized enterprises, basic rule exemption
Aggregation
Annex to EC Recommendation 2003/361
Exclusions
Generally
Medium-sized enterprise, meaning
Small enterprise, meaning
Staff headcount
Thin capitalisation
Generally
Tonnage tax
Trading stock, precedence over
Trading stock, sales at undervalue
Transaction, meaning
Transactions between dealing company and associated company
Transactions outside the transfer pricing legislation
Transfer pricing Guidelines (OECD)
UK branch of foreign partnership
Unit trusts