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Transfer pricing

26 August 2005
Categories: News
HMRC website, 17 August 2005

HMRC has recently published various information relating to transfer pricing issues following F(No.2)A 2005 which made changes to the rules from 4 March 2005. Draft guidance (on the Internet at has been published on the following aspects.

  • 'Acting together' and collective control.
  • Risk assessment - persons 'acting together'.
  • Transitional provisions.

HMRC states that final versions of the guidance will be incorporated (or cross referenced) in the International Manual which will be updated more generally to reflect the changes to transfer pricing rules but that comments can be made 'while the guidance remains on this page in draft form'.
There is an e-mail link to HMRC on the above-mentioned Internet page or contact David Hannigan ( tel 020 7147 2736) to discuss the application of the new rules.
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