BIM33650 - Stock: non-trading transactions in stock: transfer pricing and thin capitalisation
Where someone has transactions with a connected party, then transfer pricing and thin capitalisation rules may require tax to be calculated on the basis of what the 바카라 사이트˜arms length바카라 사이트™ provision would have been - if the actual provision confers a tax advantage in comparison with the 바카라 사이트˜arm's length바카라 사이트™ result.
The rules apply to transactions between UK taxpayers, as well as cross border transactions. There is an exemption for most transactions by small and medium-sized enterprises (as assessed on a 바카라 사이트˜group바카라 사이트™ basis).
Details of the current transfer pricing and thin capitalisation rules are set out in the International Manual.