Below are details of amendments that were published on 7
December 2004.
The guidance in the sections listed below has been updated to
reflect changes to transfer pricing and thin capitalisation
legislation in FA2004. (Updating of INTM500000 –
“Cross-border finance” and INTM570000 –
“Thin Capitalisation cases: practical guidance” will
follow.)
INTM550000 – “Thin capitalisation within the
European Union: the Lankhorst-Hohorst case” has been
withdrawn.
In addition to the amendments to the sections listed below, a
new module entitled “Thin Capitalisation: FA2004
legislation” is published at INTM560000.
| Section | Title and details of update |
| INTM209000 | Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax |
| INTM214000 | How the CTSA regime works for Controlled Foreign Companies |
| INTM431000 | What is transfer pricing all about? |
| INTM432000 | Schedule 28AA: how it works |
| INTM433000 | Schedule 28AA - Self Assessment obligations |
| INTM434000 | Schedule 28AA: enquiries and management provisions |
| INTM460100 | Transfer pricing: a practical guide to enquiries - introduction |
| INTM461000 | Transfer pricing: case selection |
| INTM462000 | Working a transfer pricing case |
| INTM463000 | Transfer Pricing: OECD and methodologies |
| INTM464000 | Transfer pricing: types of transactions |
| INTM465000 | Transfer pricing: tax-planning structures |
| INTM466000 | Establishing the arm's length price: examining transfer pricing reports |
| INTM467000 | Establishing the arm's length price: gathering your own evidence |
| INTM468000 | Giving transfer pricing advice to taxpayers |
| INTM469000 | Transfer Pricing: Advance Pricing Agreements ('APAs') |
| INTM470000 | Transfer pricing: addressing double taxation |
| INTM540000 | Thin capitalisation: legislation and principles |
| INTM541000 | Introduction to thin capitalisation (legislation and principles) |
| INTM542000 | Thin capitalisation: obligation to deduct withholding tax on payments of interest abroad - ICTA88/S349(2) |
| INTM544000 | Thin capitalisation: interest as a distribution - ICTA88/S209(2)(da) |
| INTM545000 | Thin capitalisation: other provisions of ICTA88/S209 |
| INTM546000 | Thin capitalisation: limitations of ICTA88/S209 |
| INTM547000 | Thin capitalisation: financial transactions - ICTA88/SCH28AA |
| INTM548000 | Thin capitalisation: Interaction of ICTA88/S209 with ICTA88/SCH28AA |
