For all accounting periods ending on or after 1 July 1999, taxpayers are obliged to make returns and self assess in accordance with the arm’s length principle. This applies as much to intra-group funding as to transactions in tangible goods. Pre 1 April 2004 it only applied to cross border intra-group loans and transfer pricing but post 1 April 2004 it also applies to intra-UK transactions. Self-Assessment obligations relating to transfer pricing are considered at INTM433000 onwards.
