Shortly after the opening correspondence and meeting it should
be possible to form a view as to the acceptability, or otherwise,
of the particular transaction with respect to the UK legislation
and the arm’s length standard. It is important that the view
be clearly communicated, since among other things it may have a
bearing on the position regarding withholding tax (see
INTM574030). The position regarding
withholding tax should be clearly stated at the same time.
At this stage it will be necessary to explore any differences
in interpretation of the UK legislation as it applies to the
particular case. This is dealt with in more detail from
INTM574000 onwards.
