International Manual Update Index - Recent changes to this manual

Below are details of amendments that were published on 17 May 2005

The guidance modules at INTM500000 – “Intra-group funding” (formerly entitled “Cross- border finance”) and INTM570000 – “Thin Capitalisation cases: practical guidance” have been updated to reflect changes to transfer pricing and thin capitalisation legislation in FA2004, further to the updates to the manual for this purpose published on 14th December 2004.
New chapters have been added to the module at INTM330000 – “DT applications and claims in CNR” as follows:
INTM345600 – Double Taxation Agreements A to Z country guide

INTM367000 – EU Directive: Interest & Royalties paid between Associated Companies – claims and applications by non-residents
The chapter “Overview of DT Agreements” formerly at INTM350000 has been moved to INTM345400
Two new modules entitled “The Non-resident Landlords Scheme” and “EU Interest and Royalties Directive” are published at INTM370000 and INTM400000 respectively
The list below shows details of other amendments to the Manual. This list does not include minor text and formatting changes or amended/additional hyperlinks

Section	Title and details of update
INTM100000	Introduction Rewritten to reflect current content of the manual and change of address of Revenue Policy International
INTM153270	Principles of Double Taxation Relief and Introduction to Double Taxation Agreements: Description of double taxation agreements: mutual agreement procedure Revenue Policy International, External Relations Group change of address
INTM157010	Principles of Double Taxation Relief and Introduction to Double Taxation Agreements: Double taxation relief: information and claims: Library & Research and Translations Revenue Policy International, Library and Research change of address
INTM161320	Double Taxation Relief: UK residents with foreign income or gains: double taxation relief: corresponding adjustments and the alternative method Revenue Policy International, Business Tax Group change of address
INTM201010	Controlled Foreign Companies: legislation: introduction and outline: guidance on the Controlled Foreign Companies’ rules under self assessment Revenue Policy International, Registry change of address
INTM214060	Controlled Foreign Companies: How the CTSA regime works for Controlled Foreign Companies: Inland Revenue Enquiries: Board’s sanction Extention to guidance covering Board’s sanction
INTM214150	Controlled Foreign Companies: How the CTSA regime works for Controlled Foreign Companies: clearances: where to send applications Revenue Policy International, Registry change of address
INTM215490	Controlled Foreign Companies: before CTSA: reliefs: disclaimer of relief: form of disclaimer Revenue Policy International change of address
INTM215530	Controlled Foreign Companies: before CTSA: losses: pre-direction losses: form of claim Revenue Policy International change of address
INTM345040	DT applications and claims in CNR: manufactured payments additional text concerning manufactured overseas dividends paid on or after 1 November 2003
INTM468000	Giving transfer pricing advice to taxpayers Rewritten to take account of the changes in FA2004 and of the guidance on intra-group service provision which is now included at INTM464055
INTM504010	Intra-group funding: inward investment: enquiries concerning investment from abroad Revenue Policy International change of address
INTM572030	Thin capitalisation: practical guidance: the start of a case Revenue Policy International change of address

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