International Manual - Recent changes to this manual
Below are details of amendments published on 29 December 2006
(see the
update index for all updates).
The amendments are extensive but they are mostly relatively
minor text and formatting changes, amended/additional hyperlinks or
changes to names and titles (e.g. Inland Revenue to HM
Revenue and Customs) following departmental restructuring.
The more substantive changes are listed below.
| Section | Title and details of update |
| INTM202040 | Controlled Foreign Companies: definitions: accounting
periods
Additional section dealing with accounting periods beginning on or after 3 December 2004 |
| INTM202050 | Controlled Foreign Companies: definitions:
residence
Additional text under Companies with no territory of residence - Excluded Countries Regulations to deal with accounting periods beginning on or after 3 December 2004 |
| INTM203040 | Controlled Foreign Companies: exemptions – excluded
countries: Meaning of ‘Resident’
Additional section dealing with accounting periods beginning on or after 3 December 2004 |
| INTM203050 | Controlled Foreign Companies: exemptions – excluded
countries: income and gains requirement
Additional section dealing with accounting periods beginning on or after 3 December 2004 |
| INTM203060 | Controlled Foreign Companies: exemptions – excluded
countries: commercially quantified income
Additional section dealing with accounting periods beginning on or after 3 December 2004 |
| INTM203070 | Controlled Foreign Companies: exemptions – excluded
countries: non-local source income
Additional section dealing with accounting periods beginning on or after 3 December 2004 |
| INTM206050 | Controlled Foreign Companies: exemptions – public
quotation condition: Recognised Stock Exchange
Updated list |
| INTM262020 | Non-residents trading in the UK: domestic charging
provisions: UK legislation – charging provisions
New text to cover enactment of ITTOIA05 |
| INTM262030 | Non-residents trading in the UK: domestic charging
provisions: non-residents – Income Tax charge
New text to cover enactment of ITTOIA05 |
| INTM262040 | Non-residents trading in the UK: domestic charging
provisions: non-resident companies - Corporation Tax charge:
ICTA88/S11
New text to cover enactment of ITTOIA05 |
| INTM263000 | Non-residents trading in the UK: trading in the UK
New text to cover enactment of ITTOIA05 |
| INTM264020 | Non-residents trading in the UK: domestic law permanent
establishment/branch or agency: importance of the concept of
permanent establishment/branch or agency to effective taxation of
non-residents
New text to cover enactment of ITTOIA05 |
| INTM267030 | Non-residents trading in the UK: profits of the PE:
domestic provisions on quantifying chargeable profits - Income Tax
and Corporation Tax
New text to cover enactment of ITTOIA05 |
| INTM268020 | Non-residents trading in the UK: ‘Machinery
provisions for assessment and collection via UK representatives:
Who can be the non-resident's UK representative?
New second paragraph/sub-paras i and iii under Who cannot be a UK representative |
| INTM269170 | Non-residents trading in the UK: transactions carried out
through UK investment managers, brokers or Lloyds agents:
investment managers exemption – income tax – casual
agents
Page deleted - Guidance previously on this page is now incorporated at INTM268020 |
| INTM269180 | Non-residents trading in the UK: transactions carried out
through UK investment managers, brokers or Lloyds agents: limit to
Income Tax charge on non-residents
Final paragraph rewritten |
| INTM330840 | DT applications and claims: time limit before
1996/97
Page deleted |
| INTM331026 | DT applications and claims: self assessment –
repayment claims for non-residents: introduction of new style claim
forms
Page deleted |
| INTM331027 | DT applications and claims: self assessment –
repayment claims for non-residents: claim on an old form
New instructions referring to current form |
| INTM333130 | DT applications and claims: Vouchers: microfilmed
vouchers
Page deleted |
| INTM333160 | DT applications and claims: Vouchers: Vouchers showing
Foreign Income Dividends
Page deleted |
| INTM333190 | DT applications and claims: Vouchers: What the block
voucher clerk does
Page deleted |
| INTM333200 | DT applications and claims: Vouchers: How block vouchers
are received in this office
Page deleted |
| INTM333250 | DT applications and claims: Vouchers: Vouchers showing
Income Tax deducted in foreign currency
Page deleted |
| INTM333280 | DT applications and claims: Vouchers: What to do with an
original Voucher received after payment
Page deleted |
| INTM334580 | DT applications and claims: applicants/claimants –
individuals
Additional text at eighth bullet to allow for the provisions of the Civil Partnerships Act |
| INTM338010 | DT applications and claims: applicants/claimants: Overseas
Collecting Societies
Deletion from bulleted list of “Performing right fees paid by Performing Artists Media Rights Association |
| INTM338070 | DT applications and claims: applicants/claimants: Overseas
Collecting Societies: Performing Artists Media Rights Association
(PAMRA)
Page deleted |
| INTM342540 | DT applications and claims: Types of income: Royalties:
copyright royalties continued
Updated final paragraph |
| INTM343530 | DT applications and claims: Types of income: Dividends:
Portfolio investors continued: Dividends paid before 6 April
1999
Page deleted |
| INTM344520 | DT applications and claims: Types of income: Other
income
Revised text under UK unauthorised unit trusts and new final section headed Annual payments that are not interest or royalties |
| INTM367780 | DT applications and claims: Non-resident beneficiaries of
UK trusts: Distributions to a beneficiary with a discretionary or a
contingent interest
Addition to bullet text under Taxation of discretionary trusts to show position from 6 April 2004 |
| INTM368020 | DT applications and claims: FOTRA securities: Background:
Before 6 April 1998
Page deleted |
| INTM508040 | Intra-group Funding: ‘thinning out’: commercial
considerations
New final sentence |
| INTM508060 | Intra-group Funding: ‘thinning out’: How to
tackle ‘thinning out’
New section For accounting periods commencing on or after 1 April 2004 |
| INTM509130 | Intra-group Funding: avoidance and arbitrage: What is
arbitrage?
New final sentence in first paragraph |
| INTM541005 | Introduction to thin capitalisation (legislation and
principles): the importance of 1st April 2004
New page |
| INTM541030 | Introduction to thin capitalisation (legislation and
principles): Tax effects of different methods of funding I
Additional text in fourth paragraph beginning with the words “This is also known as tax arbitrage.” |
| INTM541040 | Introduction to thin capitalisation (legislation and
principles): Tax effects of different methods of funding
II
Additional text in final paragraph beginning with the words “- known as tax arbitrage.” |
| INTM541060 | Introduction to thin capitalisation (legislation and
principles): Use of indirect funding methods
New final sentence in third paragraph |
| INTM544010 | Thin capitalisation: interest as a distribution –
Introduction to ICTA88/S209(2)(da) (repealed)
New first paragraph |
| INTM544030 | Thin capitalisation: interest as a distribution -
ICTA88/S209(2)(da) (repealed): Provisions of
ICTA88/S209(2)(da)
New first paragraph |
| INTM544050 | Thin capitalisation: interest as a distribution -
ICTA88/S209(2)(da) (repealed): Factors to be taken into account
when considering whether ICTA88/S209(2)(da) applies:
ICTA88/S209(8C)
New fourth bullet |
| INTM544070 | Thin capitalisation: interest as a distribution -
ICTA88/S209(2)(da) (repealed): Meaning of effective 51%
subsidiaries
New first paragraph |
| INTM544080 | Thin capitalisation: interest as a distribution -
ICTA88/S209(2)(da) (repealed): Treatment of companies which do not
meet the definition of a 51% subsidiary
New first paragraph |
| INTM546020 | Thin capitalisation: limitations of ICTA88/S209(2)(da):
Non-excessive interest payable to a tax haven
New text in final paragraph after the words “See the chapter on arbitrage at INTM509000 onwards” |
| INTM572020 | Thin capitalisation: the start of a case: Practical aspects
of a pre-return enquiry
New final sentence in second paragraph |
| INTM572030 | Thin capitalisation: the start of a case: Referral to CT
& VAT, International CT – Monetary limits
New text in first paragraph after first sentence |
| INTM572035 | Thin capitalisation: the start of a case: Referral to CT
& VAT, International CT – Other reasons
New page |
| INTM502040 | Thin capitalisation: the start of a case: Risk
assessment Under
Timing of an enquiry, revised text under new
sub-heading “Claims made under the provisions of a double
taxation agreement” and new text under new sub-heading
“Claims made under the provisions of the EU Interest &
Royalties Directive”
|
| INTM573010 | Thin capitalisation: filling in form 4450/1: Information
supplied on form 4450/1
New first paragraph and updated bullets showing information requirements |
| INTM573020 | Thin capitalisation: filling in form 4450/1: The need for
timely completion of the form
New opening paragraph at 1. |
| INTM579050 | Thin capitalisation: debt:equity ratio: The UK borrowing
unit
New first paragraph |
| INTM581010 | Thin capitalisation: practical guidance – comparison
of lending in the UK with other countries
Updates in financial ratio table for Australia, Germany and France |
| INTM582020 | Thin capitalisation: agreements between HM Revenue &
Customs and the group
New third paragraph |
