Actual provision, meaning

Adjustments

Advance pricing agreements

Generally

Affected persons, meaning

Alternative finance arrangements

Appeals

Appeals versus mutual agreement procedure

Arbitration convention

Generally

Arm's length price, determination

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

Base Erosion and Profit Shifting (BEPS)

Generally

Other BEPS related publications (non-action specific)

Basic rule

Application

Calculations to be based on arm's length principle

Dormant companies pre-1 April 2004, exemption for

Exemption from

Exemptions

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

Disposal of stock in trade and intangible assets

Diverted profits tax

Compliance and administration

Generally

Documentation

Country-by-country reporting

Existing rules

Dormant companies

Dormant companies, exemptions from basic rule

Double taxation

Compensating adjustments

EU Arbitration Convention

Mutual agreement procedure

Double taxation elimination

Election to pay tax of advantaged person, securitisation

Enquiries

EU Joint Transfer Pricing Forum

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

Partnerships

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

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

Small or medium-sized enterprises

Thin capitalisation

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

Unit trusts