UK Act of Parliament
2010
United Kingdom
Taxation (International and Other Provisions) Act 2010
At a glance
Enforced by
What's here
19 compliance obligations, 1 practical guide
Who this Act binds
Business-side actors with duties under this Act, ranked by how often they appear.
- Any Person 11
- Trader 5
- Director or Officer 2
Plus 1 non-business duty on Crown ministers, regulators, local authorities or tribunals — shown collapsed under each section below.
Relevant guidance
Practical guides for businesses affected by this Act, ordered by how closely they engage with it.
Direct — cites this Act
1 guidesOther Acts binding the same actors
For each actor bound by this Act, the other UK Acts that bind them most often. Useful for understanding the full compliance landscape facing each role.
Any Person also bound by 749 other Acts (top 5 shown)
- Human Medicines Regulations 2012 2012 110 duties
- Licensing Act 2003 2003 105 duties
- Merchant Shipping Act 1995 1995 97 duties
- Road Traffic Act 1988 1988 95 duties
- Air Navigation Order 2016 2016 86 duties
Traders also bound by 219 other Acts (top 5 shown)
- Value Added Tax Regulations 1995 1995 952 duties
- TULRCA 1992 1992 39 duties
- Companies Act 2006 2006 39 duties
- Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 2013 39 duties
- The Customs (Import Duty) (EU Exit) Regulations 2018 2018 33 duties
Directors and Officers also bound by 224 other Acts (top 5 shown)
- Insolvency (England and Wales) Rules 2016 2016 75 duties
- Companies Act 2006 2006 63 duties
- Insolvency Act 1986 1986 46 duties
- CCBSA 2014 2014 22 duties
- CAICEA 2004 2004 18 duties
What this Act requires
Sections that create concrete duties on businesses or carry penalties. Procedural and definitional sections are folded into the “Browse other sections” expander at the bottom of each group. Click any section title to read the source text on legislation.gov.uk.
Part 1 — Overview
No sections of this Part have been ingested yet.
Part 2 — Double taxation relief
Amount of limit
- Calculate and limit Foreign Tax Credit against income tax Any Person
- Calculate foreign tax credit within the statutory limit Any Person
Amount of limit
- Calculate and claim capital gains tax credit within the allowed limit Any Person
- Calculate the limit for foreign tax credit against Capital Gains Tax Any Person
Credit against tax on trade income
- Calculate and claim corporation tax credit on trade income correctly Director or Officer
- Limit foreign tax credits against your trade income Trader
Limit on credit in cases involving qualifying loan relationships of CFCs
- Calculate and limit loan‑relationship tax credit for UK companies with CFC links Trader
- Limit foreign tax credit claims for certain CFC loan relationships Trader
Applying section 42(2) to non-trading credits from loan relationships etc
- Calculate foreign tax credit limits for non‑trading credits Director or Officer
- Limit foreign tax credit claims on non-trading loan relationship income Trader
Duty to give notice that adjustment has rendered credit excessive
- Notify HMRC if foreign tax credit is reduced or becomes excessive Any Person
- Notify HMRC if foreign tax credits become excessive Any Person
Interpreting sections 99 to 101 for life assurance or gross roll-up business
Amended 1 timeInterpreting sections 100 and 101: amounts referable to category of business
Amended 1 timeDeduction from income for foreign tax (instead of credit against UK tax)
Amended 8 timesDuty to give notice that adjustment has rendered reduction too large
- Notify HMRC if a foreign tax adjustment makes your UK tax relief too high Any Person
- Notify HMRC if a foreign tax reduction becomes too large Any Person
Tax treated as chargeable in respect of transfer of loan relationship, derivative contract or intangible fixed assets
Amended 2 timesIntroduction to section 119
Amended 13 timesTax treated as chargeable in respect of transfer of loan relationship, derivative contract or intangible fixed assets
Amended 2 timesIntroduction to section 121
Amended 2 timesTax treated as chargeable in respect of relevant transactions
Amended 1 timeTax treated as chargeable in respect of gains on transfer of non-UK business
Amended 1 timeGiving effect to solutions to cases and mutual agreements resolving cases
Amended 1 timeSpecial relationship rule for royalties: matters to be shown by taxpayer
- Show HMRC that royalty payments are at a fair market rate Any Person
- Show no special relationship or calculate royalty rates for HMRC Trader
Browse 84 other sections in this Part — procedural / definitional / commencement
Giving effect to arrangements made in relation to other territories
Arrangements may include retrospective or supplementary provision
Meaning of “double taxation” in sections 2 and 3
Orders under section 2: contents and procedure
General regulations
Interpretation: “ unilateral relief arrangements ” means rules 1 to 9, etc
Rule 4: cases in which, and calculation of, credit allowed for tax on dividends
Rule 5: credit for tax charged directly on dividend
Rule 7: credit for underlying tax on dividend paid to sub-10% associate
Rule 8: credit for underlying tax on dividend paid by exchanged associate
Entitlement to credit for foreign tax reduces UK tax by amount of the credit
Time limits for claims for relief under section 18(2)
Foreign tax includes tax spared because of international development relief
Meaning of “the arrangements”, “the non-UK territory”, “foreign tax” etc
Time limits for claims for relief under section 22(2)
Credit not allowed if relief allowed against overseas tax
Credit not allowed if person elects against credit
Unilateral relief for Isle of Man or Channel Islands tax
Unilateral relief for non-UK tax on non-resident's UK branch or agency etc
Calculation of income or gain where remittance basis does not apply
Calculation of amount received where UK tax charged on remittance basis
Credit against tax on trade income: further rules
Credit reduced by reference to accrued income losses
Amount of limit
Profits attributable to permanent establishments for purposes of section 42(2)
Credit against tax on trade income: anti-avoidance rules
Applying section 44(2): asset in hedging relationship with derivative contract
Applying section 44(2): royalty income
Applying section 44(2): “portfolio” of transactions, arrangements or assets
Restricting section 44(3) if company is a bank or connected with a bank
Tax for period on intangible fixed assets
General deductions
Earlier years' non-trading deficits on loan relationships
Non-trading debits on loan relationships
Current year's non-trading deficits on loan relationships
Calculation if dividend paid by non-resident company to resident company
Meaning of “relevant profits” in section 58
Calculation if section 58 does not apply
Non-UK company dividend paid to 10% investor: relief for UK and other tax
Relief for underlying tax paid by company lower in dividend-paying chain
Limitations on section 65(4)
Restriction of relief if underlying tax at rate higher than rate of corporation tax
Meaning of “avoidance scheme” in section 67
Foreign taxation of group as single entity
Circumstances in which section 71B applies
Reduction of foreign tax paid on profits of overseas PE
Rules for carrying back unrelieved foreign tax
Two or more establishments treated as a single establishment
Former and subsequent establishments regarded as distinct establishments
Meaning of “overseas permanent establishment”
Time limits for action if tax adjustment makes credit excessive or insufficient
Conditions for the purposes of section 81(1)
Schemes and arrangements referred to in section 82(4)
Section 83(2) and (4): schemes about effect of paying foreign tax
Section 83(2) and (4): schemes involving deemed foreign tax
Section 83(2) and (4): schemes about claims or elections etc
Section 83(2) and (4): schemes involving tax-deductible payments
Contents of counteraction notice
Consequences of counteraction notices
Counteraction notices given before tax return made
Amendment, closure notices and discovery assessments in section 92 cases
Information made available for the purposes of section 92(4)
Interpretation of sections 89 to 94
Companies with overseas branches: restriction of credit
Commercial allocation of relevant income to different categories of long-term business
Allocation of expenses etc in calculations under section 35 of CTA 2009
Second limitation for purposes of section 99(2)
Meaning of “chargeable gain”
Disregard of foreign tax referable to derivative contract
Disregard of foreign tax attributable to interest under a loan relationship
Repo cases in which no disregard under section 108
Stock-lending cases in which no disregard under section 108
Deduction from capital gain for foreign tax (instead of credit against UK tax)
Time limits for action if tax adjustment makes reduction too large or too small
Effect of, and deadline for, presenting a case
Meaning of “the Arbitration Convention”
Giving effect to agreements, decisions and opinions under the Convention
Disclosure under the Convention
Power by regulations to give effect to international obligations etc
Giving effect to requirements under section 128A regulations
Disclosure where relief given overseas for tax paid in the United Kingdom
Interpreting provision about UK taxation of profits of foreign enterprises
Interpreting provision about royalties influenced by special relationship
Correcting assessments where relief is available
Part 3 — Double taxation relief for special withholding tax
Browse 6 other sections in this Part — procedural / definitional / commencement
Relief under this Part: introductory
Income tax credit etc for special withholding tax
Capital gains tax credit etc for special withholding tax
Provisions about the deemed tax under section 139
Credit under Chapter 2 of Part 2 to be allowed first
Refusal to issue certificate and appeal against refusal
Part 4 — Transfer pricing
Tax calculations to be based on arm's length, not actual, provision
Amended 6 timesThe “participation condition”
Amended 10 times“Arm's length provision”
Amended 2 timesArm's length provision where actual provision relates to securities
Amended 1 timeArm's length provision where security issued and guarantee given
Amended 1 timeInterpretation of sections 152 and 153
Amended 7 times“ Potential advantage ” in relation to United Kingdom taxation
Amended 1 timeIndirect participation: potential direct participant
Amended 11 timesIndirect participation: one of several major participants
Amended 10 timesMeaning of “connected” in section 159
Amended 1 timePart to be interpreted in accordance with OECD principles
Amended 9 timesExemption for small and medium-sized enterprises
Amended 2 timesAppeals against transfer pricing notices
Amended 5 timesTax returns where transfer pricing notice given
Amended 3 timesClaim by the affected person who is not potentially advantaged
Amended 6 timesClaims under section 174 where disadvantaged person within charge to income tax
Amended 6 timesClaims under section 174: advantaged person must have made return
Amended 1 time- Ensure tax returns reflect arm's length calculations before making a claim Any Person
- Make a tax return calculation on an arm’s‑length basis before claiming relief Any Person
Compensating payment if advantaged person is controlled foreign company
Amended 6 timesSection 182 applies to claims where actual provision relates to a security
Amended 3 timesWhen sections 192 to 194 apply
Amended 9 timesProvision for cases within Part 6A
Amended 8 timesInteraction between claims under sections 174 and 192(1)
Amended 7 timesBalancing payments by guarantor to issuer: no charge to, or relief from, tax
Amended 7 timesPre-conditions for making election under section 200
Amended 3 timesElection to pay tax rather than make balancing payments
Amended 3 timesPre-conditions for making election under section 202
Amended 2 timesElection, in guarantee case, to pay tax rather than make balancing payments
Amended 3 timesThe requirement for the Commissioners' sanction
Amended 1 timeCapital allowances
Amended 1 timeBrowse 21 other sections in this Part — procedural / definitional / commencement
Application of this Part
Medium-sized enterprises: exception from exemption: transfer pricing notice
Giving of transfer pricing notices
Meaning of “qualifying territory” and “non-qualifying territory”
Time for making, or amending, claim under section 174
Meaning of “return” in sections 176 and 177
Application of section 174(2)(a) in relation to transfers of trading stock etc
Making of section 182 claims
Amending a section 182 claim if it is followed by relevant notice
Qualifying conditions for purposes of section 196
Balancing payments between affected persons: no charge to, or relief from, tax
Meaning of “capital market condition” in sections 199 and 201
Provision made or imposed between ring-fence trade and other activities
Meaning of “oil-related ring-fence trade” in sections 205 and 218
Modification of basic rule where allowances restricted for certain expenditure
The determinations which require the Commissioners' sanction
Determinations exempt from requirement for Commissioners' sanction
Restriction of right to appeal against Commissioners' approval
Appeals
Manner of making adjustments to give effect to Part
Meaning of “control” and “firm”
Part 4A — Assessment of unassessed transfer pricing profits
No sections of this Part have been ingested yet.
Part 5 — Advance pricing agreements
Modifications of agreement for double taxation purposes
Other duties (1) — Crown / regulator
- HMRC must modify Advance Pricing Agreements to match international tax treaties Statutory regulator
Browse 7 other sections in this Part — procedural / definitional / commencement
Meaning of “advance pricing agreement”
Effect of agreement on party to it
Effect of revocation of agreement or breach of its conditions
Effect of agreement on non-parties
Provision in agreement about years ended or begun before agreement made
Annulment of agreement for misrepresentation
Interpretation of Part: meaning of “Commissioners” and “officer”
Part 6 — Tax arbitrage
Overview
Amended 2 timesSchemes achieving UK tax advantage for a company
Amended 1 timeSchemes involving hybrid entities
Amended 1 timeNotices given after tax return made
Amended 3 timesAmendments, closure notices and discovery assessments where section 256 applies
Amended 2 timesBrowse 14 other sections in this Part — procedural / definitional / commencement
Deduction notices
Securities subject to conversion
Debt instruments treated as equity
Scheme including issue of shares not conferring qualifying beneficial entitlement
Scheme including transfer of rights under a security
Consequences of deduction notices
Cases where payee's non-liability treated as not a result of scheme
Cases where payee treated as having reduced liability as a result of scheme
The rule against deduction for untaxable payments
The receipt scheme conditions
Exception for dealers
Rule for calculation or recalculation of income etc following receipt notice
Notices given before tax return made
Schemes and series of transactions
Part 6A — Hybrid and other mismatches
Browse 59 other sections in this Part — procedural / definitional / commencement
“ Tax ” means certain taxes on income and includes foreign tax etc
References to equivalent provision to this Part under the law of a territory outside the United Kingdom
Chargeable companies in respect of CFCs and foreign CFCs
Meaning of “hybrid entity”, “investor” and “investor jurisdiction”
Meaning of “permanent establishment”
Overview of Chapter
Circumstances in which the Chapter applies
Hybrid or otherwise impermissible deduction/non-inclusion mismatches and their extent
Overview of Chapter
Circumstances in which the Chapter applies
Interpretation of section 259DC
Counteraction where the payer is within the charge to corporation tax for the payment period
Overview of Chapter
Hybrid payer deduction/non-inclusion mismatches and their extent
Counteraction where the hybrid payer is within the charge to corporation tax for the payment period
Overview of Chapter
Counteraction of the excessive PE deduction
Overview of Chapter
Circumstances in which the Chapter applies
Hybrid payee deduction/non-inclusion mismatches and their extent
Counteraction where the payer is within the charge to corporation tax for the payment period
Counteraction where the investor is within the charge to corporation tax
Counteraction where a hybrid payee is an LLP
Overview of Chapter
Multinational payee deduction/non-inclusion mismatches and their extent
Overview of Chapter
Circumstances in which the Chapter applies
Counteraction where the investor is within the charge to corporation tax
Counteraction where the hybrid entity is within the charge to corporation tax
Counteraction where mismatch arises because of a dual resident company
Counteraction where mismatch arises because of a relevant multinational and the UK is the parent jurisdiction
Counteraction where mismatch arises because of a relevant multinational and is not counteracted in the parent jurisdiction
Meaning of excessive PE inclusion income
Overview of Chapter
Circumstances in which the Chapter applies
Meaning of “dual territory double deduction”, “excessive PE deduction” and “PE jurisdiction”
Denial of the relevant deduction in relation to the imported mismatch payment
Deductions from dual inclusion income
Limit on reduction under section 259KC
Adjustments where suppositions cease to be reasonable
Countering the effect of avoidance arrangements
Application of Chapter 9
Application of Chapter 11
Meaning of “financial instrument”
Meaning of “relevant investment fund”
Control groups
Related persons
Treatment of a person who is a member of a partnership
Priority
Release of debts
Release of connected companies debts
Release of connected companies debts during creditor’s insolvency
Corporate rescue: debt released shortly after connection arises
Overview of Chapter
Circumstances in which Chapter applies
Claims for allocation of DII surplus
The unused part of the DII surplus
Groups of companies
Meaning of “dual inclusion income” and “counteraction amount”
Part 7 — Tax treatment of financing costs and income
Introduction
Amended 1 timeUK net debt of worldwide group for period of account of worldwide group
Amended 5 timesNet debt of a company
Amended 1 timeReferences to amounts disclosed in balance sheet of a company
Amended 3 timesDifferent accounting treatment used at company and group levels
Amended 3 timesInsurance activities and insurance-related activities
Amended 1 timeRelevant dealing in financial instruments
Amended 3 timesUK trading income of the worldwide group
Amended 5 timesForeign currency accounting
Amended 3 timesStatement of allocated disallowances: requirements
Amended 1 timeStatement of allocated disallowances: dual resident investing companies
Amended 1 timeSection 284: supplementary
Amended 4 timesStatement of allocated exemptions: requirements
Amended 6 timesFailure of reporting body to submit statement of allocated exemptions
Amended 3 timesApplication of Chapter to financing income amounts determined under section 314A
Amended 2 timesMeaning of “carried-back amount” and “carried-forward amount”
Amended 2 timesThe financing expense amounts of a company
Amended 2 timesThe financing income amounts of a company
Amended 5 timesGroup treasury companies
Amended 4 timesShort-term loan relationships
Amended 2 timesEducational and public bodies
Amended 5 timesGroups containing securitisation companies
Amended 8 timesPartnerships: other expenses
Amended 8 timesThe worldwide group
Amended 2 timesMeaning of “ultimate parent”
Amended 3 timesFinancial statements of the worldwide group
Amended 1 timeNon-existent financial statements of the worldwide group
Amended 3 timesFinancial statements: business combinations to which the worldwide group is a party
Amended 3 timesRegulations and orders
Amended 4 timesBrowse 44 other sections in this Part — procedural / definitional / commencement
Qualifying activities
Lending activities and activities ancillary to lending activities
Worldwide trading income of the worldwide group
Meaning of “dual resident investing company”
Statement of allocated disallowances: submission
Statement of allocated disallowances: submission of revised statement
Statement of allocated disallowances: effect
Company tax returns
Power to make regulations about statement of allocated disallowances
Powers to make regulations in relation to reductions under section 284
Meaning of “company to which this Chapter applies”
Meaning of “the reporting body”
Statement of allocated exemptions: submission
Statement of allocated exemptions: submission of revised statement
Company tax returns
Power to make regulations about statement of allocated exemptions
Power to make regulations in relation to reductions under section 296
Meaning of “tax-resident” and “EEA territory”
Qualifying EEA tax relief for payment in current or previous period
Schemes involving manipulation of rules in Chapter 2
Schemes involving manipulation of rules in Chapters 3 and 4
Calculation of amounts
Schemes involving manipulation of rules in Chapter 5
Meaning of “scheme” and “excluded scheme”
Companies with permanent establishments profits election
Companies engaged in oil extraction activities
Intra-group short-term finance: financing expense
Stranded deficits in non-trading loan relationships: financing income
Stranded management expenses in non-trading loan relationships: financing income
Interpretation of sections 316 to 327
Companies with net financing deduction or net financing income that is small
Mismatches between tax treatment and accounting treatment
Elections disapplying sections 329(5) and 330(5)
Group members with income from shipping subject to particular tax treatment in UK
Group members with income from property rental subject to particular tax treatment in UK
Meaning of accounting expressions used in this Chapter
Mismatches between tax treatment and accounting treatment
Meaning of “group”
Meaning of “corporate entity”
Meaning of “relevant non-corporate entity”
Treatment of business combinations
Meaning of “ large ” in relation to a group
Non-compliant financial statements of the worldwide group
Translation of amounts disclosed in financial statements
Part 8 — Offshore funds ETC
Browse 7 other sections in this Part — procedural / definitional / commencement
Meaning of “offshore fund”
Meaning of “mutual fund”
Meaning of “relevant income-producing asset”
Power to make regulations about exceptions to definition of “mutual fund”
Treatment of umbrella arrangements
Treatment of arrangements comprising more than one class of interest
Meaning of “participant” and “participation”
Part 9 — Amendments to relocate provisions of tax legislation
Browse 6 other sections in this Part — procedural / definitional / commencement
Part 9A — Controlled foreign companies
Browse 76 other sections in this Part — procedural / definitional / commencement
Overview of Part
Introduction to the CFC charge
The CFC charge gateway
Chargeable companies
Companies which are managers of offshore funds etc
Companies which are participants in offshore funds
Does Chapter 4 apply?
Does Chapter 5 apply?
Section 371CE: meaning of “group treasury company”
Does Chapter 8 apply?
Introduction to Chapter
The steps
Exclusion: UK activities a minority of total activities
Exclusion: trading profits (the basic rule)
Exclusion: trading profits (business premises condition)
Exclusion: trading profits (management expenditure condition)
Exclusion: trading profits (IP condition)
Exclusion: trading profits (export of goods condition)
The basic rule
UK activities
The basic rule
Loans from foreign permanent establishments of UK resident companies
Exclusion: insurance business
The basic rule
The basic rule
The basic rule
The “matched interest profits” exemption
Determining the profits of a qualifying loan relationship
Power to amend definitions
Introduction to Chapter
How long is an exempt period?
Anti-avoidance
Amendment of company tax returns
What is “the threshold amount”?
Category B income
Category C income
Category D income
The IP condition
Introduction to Chapter
Anti-avoidance
The basic rule
Reductions to “the local tax amount”
What are “designer rate tax provisions”?
Application of Chapter
Provision about interpretation
“Relevant interests” of persons related to UK resident companies
Application of Chapter
The basic rules
Apportionments to be made in proportion to shareholding
Variable shareholdings
Legal and economic control
Legal and economic control: the 40% rule
Companies in which a UK resident company has more than a 50% investment
Overview of Chapter
UK residence etc
Close company
Claims and elections
Restrictions on certain deductions: deductions allowances
Capital allowances
Unremittable overseas income
Tax advantages
Shares accounted for as liabilities: application of section 521C of CTA 2009
Double taxation relief: countering effect of avoidance arrangements
The basic rule
How to determine the territory in which the CFC is resident
Introduction to Chapter
Application of the Taxes Acts to the CFC charge
Payments in respect of a charge on a banking company: information to be provided
Just and reasonable apportionments
Appeals affecting more than one person
Accounting periods
Cell companies etc
Finance profits
Interests in companies
Property business profits
Relevant finance leases
Part 10 — Corporate interest restriction
Disallowance of deductions: full interest restriction return submitted
Amended 1 timeDisallowed tax-interest expense amounts carried forward
Amended 2 timesAmount of interest allowance for a period that is “available” in a later period
Amended 1 timeAmounts not brought into account in determining a company's tax-EBITDA
Amended 5 timesNet group-interest expense
Amended 1 time“Relevant expense amount” and “relevant income amount”
Amended 8 timesSection 411: interpretation
Amended 8 timesAdjusted net group-interest expense
Amended 15 timesSection 414: interpretation
Amended 4 timesGroup-EBITDA
Amended 2 timesCapitalised interest brought into account for tax purposes in accordance with GAAP
Amended 7 timesChanges in accounting policy
Amended 4 timesElections under section 433
Amended 2 timesGroup elections modifying the operation of sections 433 and 434
Amended 4 timesApplication of section 438: certain creditors treated as qualifying infrastructure companies
Amended 1 timeInterest capacity for group with qualifying infrastructure company etc
Amended 1 timeJoint venture companies
Amended 1 timePartnerships and other transparent entities
Amended 1 timeReal Estate Investment Trusts
Amended 6 timesAttribution of rights and interests
Amended 1 timeMeaning of “non-consolidated subsidiary” and “consolidated subsidiary”
Amended 4 timesOther interpretation
Amended 4 timesBrowse 62 other sections in this Part — procedural / definitional / commencement
Overview
Interest restriction returns
Disallowance of deductions: identification of the tax-interest amounts to be left out of account
Reactivation of deductions: identification of the tax-interest amounts to be brought into account
The tax-interest income amounts of a company
Relevant loan relationship credits
Amounts capitalised in carrying value of intangible fixed assets
The interest capacity of a worldwide group for a period of account
Carry forward of interest allowance: new holding company
The interest allowance of a worldwide group for a period of account
Basic interest allowance calculated using fixed ratio method
The debt cap
Effect of group ratio (blended) election on group ratio percentage
Effect of group ratio (blended) election on group ratio debt cap
Calculations under sections 401 and 402: investor worldwide groups
The tax-EBITDA of a company
Excluded relevant intangibles debits and excluded relevant intangibles credits
The capital (expenditure) adjustment
The capital (fair value movement) adjustment
The capital (disposals) adjustment
Derivative contracts subject to fair value accounting: interpretation
Group-EBITDA (chargeable gains) election
Employers' pension contributions
Unpaid employees’ remuneration
Employee share acquisitions
Section 427: associated worldwide groups
Interest allowance (consolidated partnerships) election
Interpretation of Chapter
Overview of Chapter
Loans etc made by qualifying infrastructure companies to be ignored
Joint venture groups
Decommissioning
Minor definitions for purposes of this Chapter
Oil and gas
Members of Lloyd's
Investments held by investment managers
Elections under section 456: deemed debits and credits
Counteracting effect of avoidance arrangements
Expressions relating to “related parties”: introduction
Whether a person is generally a “related party” of another
Meaning of “25% investment”
Debts with same rights where unrelated parties hold more than 50%
Debt restructuring
Ordinary independent financing arrangements by banks and others
Finance leases granted before 20 March 2017
Meaning of “a worldwide group”, “ultimate parent” etc
Interpretation of section 473: “relevant entity”
Continuity of identity of a worldwide group through time
Treatment of business combinations
“Financial statements” of a worldwide group
“Period of account” of worldwide group
Actual financial statements not drawn up on acceptable principles
Actual financial statements drawn up on acceptable principles but consolidating wrong subsidiaries
Actual financial statements covering more than one worldwide group
No actual financial statements: other cases
Election altering period of account deemed under section 485
Actual financial statements ignored if for too long a period or too late
Meaning of “relevant public body”
Meaning of “ UK group company”
Embedded derivatives
Change in accounting standards
Regulations
Part 11 — General provisions
Schedules
Browse 4 other Schedules — structural / supplementary
Miscellaneous relocations
Repeals and revocations
Alternative finance arrangements
Interest restriction returns
Official guidance
Authoritative sources published by regulators or government explaining this legislation.
- Country-by-Country Reporting guidance (opens in a new tab) Detailed Guidance
- HMRC Statement of Practice 1 (2010) - Transfer Pricing Methodology (opens in a new tab) Publication
- HMRC guidance on OECD Transfer Pricing Guidelines (opens in a new tab) Detailed Guidance
- HMRC International Manual - Transfer Pricing (opens in a new tab) Detailed Guidance
Enforcement and responsible bodies
The regulators that administer or enforce this legislation.
HM Revenue & Customs
Tax collection, customs duties, national insurance, tax credits, and enforcement of the National Minimum Wage. Regulates all UK businesses for tax compliance …
Explore more
Browse legislation
Find other UK business legislation with related guidance.
Regulators
Learn more about the bodies that enforce this legislation.