International Manual - Recent changes to this manual
Below are details of the amendments that were published on 16
November 2007 (see the
update index for all updates).
This list does not include minor text and formatting
changes or amended/additional hyperlinks
| Section | Details of update |
| INTM461000 – INTM461250 | Each chapter title amended to Transfer Pricing: risk assessment and case selection |
| INTM461020 | Additional sentence in
3rd para – shown below in red
“Where two businesses are related with each other, the amount of the taxable profit of each can be significantly affected by the results of the transactions between them. There is scope, either through manipulation or insufficient attention to the arm’s length principle, for the taxable profit of a business to be significantly depressed. The same applies where persons who collectively control a business act together (see INTM461260 for additional advice on risk assessment in relation to such “acting together”). A decision by HM Revenue & Customs whether to make an enquiry into a particular tax return needs to take account of this possibility.” |
| INTM461260 | New page: Risk assessment – persons “acting together” |
