INTMUPDATE100119 | International Manual: recent changes
From HM Revenue & Customs · International Manual
Below are details of the amendments that were published on 19 January 2010 (see the update index for all updates)
| Section | Details of update |
| INTM168022 | New page concerning an Anti-avoidance provision (at ICTA88/S798B(4) and (4A)) where there is trade income which would be received by another company as investment income. |
| INTM433030 | This page has been shortened and some of the information which was in it is now in INTM433040 and INTM433050 |
| INTM433040 | This is a new page created as a result of the shortening of INTM433030. It contains information on the exposure to penalties as part of the self assessment obligations of a company. |
| INTM433050 | This is a new page created as a result of the shortening of INTM433030. It contains information regarding the OECD guidelines on how a business can attempt to demonstrate an “arms length” result. |
| INTM434010 | Alteration of the guidance to take into account that from 1 April 2008 Transfer Pricing enquiries are subject to the governance rules and there must be the approval of the Transfer Pricing Panel or Board before a Transfer Pricing enquiry can be opened. |
| INTM434020 | This page has been altered to take into account the new Compliance Check Regulations which are in effect from 1 April 2009. |
| INTM434050 | This page has been updated to reflect that from 1 April 2008 a Transfer Pricing enquiry has to be closed in line with the governance procedures and with the permission of the Transfer Pricing Panel or Board. |
| INTM434060 | This page has been amended to take into account the new enquiry time limits which FA08/SCH39 introduces. |
| INTM434070 | There have been changes to this page which reflect the new Tribunal process which has been in place since 1 April 2009. |
| INTM436010 | This update clarifies the expected usage of ICTA88/S770 and it also includes reference to the new Tribunal process. |
| INTM460180 | This page now has a reminder that the governance process must be adhered to when opening and closing an enquiry. The Transfer Pricing Panel or Board should be involved in both instances. |
| INTM461010 | This update contains a reminder that the governance process has to be followed for transfer pricing enquiries. |
| INTM461020 | This page has been altered so that it now contains a reminder to submit a business case to the Transfer Pricing Panel when a transfer pricing enquiry is appropriate. CCM’s and Tax Specialists should contact the Transfer Pricing Group to ensure consistency in the risk assessment process. |
| INTM461050 | There is now a reminder on this page that the tax at risk should be listed in the Stage Gate 1 and that it needs to be kept under review throughout the enquiry. |
| INTM461200 | This update has a reminder that the governance process needs to be used for transfer pricing enquiries. |
| INTM462010 | This page has been rewritten to include mention of the new governance process. |
| INTM462020 | This page is now about Other legislation and issues. This emphasises the need for an Inspector to look at more than just the Transfer Pricing issues when they are working a transfer pricing case. |
| INTM462030 | This page now contains guidance on timetabling the transfer pricing enquiry. |
| INTM462040 | This page is now about working the enquiry and it gives practical advice about what is required to do this. |
| INTM462050 | This update contains information about obtaining transfer pricing reports. |
| INTM462070 | This page outlines how and when it is appropriate to use exchange of information, and how to get the best from the facility. |
| INTM462080 | The updates for this page emphasise the need to follow the governance process when settling a transfer pricing case, including obtaining approval from the Transfer Pricing Panel or Board for the settlement. |
| INTM462120 | The amendment states that the governance process should be followed when considering issuing a penalty to the business in a transfer pricing case. |
| INTM462130 | The update to this page discusses post-settlement issues, including APA’s which are the only way to agree future years with HM Revenue & Customs. |
| INTM164155 | This page has been updated so that it now refers to ICTA88/S799(2A), instead of FA05/S85, with regard to tax deductions for dividends. |