Guidance

Transfer pricing: transactions between connected companies

How transactions between connected companies should be priced for UK tax purposes.

Overview

The UK鈥檚 transfer pricing legislation details how transactions between connected parties are handled and in common with many other countries is based on the internationally recognised .

The UK legislation allows only for a transfer pricing adjustment to increase taxable profits or reduce a tax loss. It is not possible to decrease profits or increase a tax loss.

The UK鈥檚 legislation also applies to transactions between any connected UK entities.

The 鈥榓rm鈥檚 length principle鈥� applies to transactions between connected parties. For tax purposes such transactions are treated by reference to the profit that would have arisen if the transactions had been carried out under comparable conditions by independent parties.

Exemptions

罢丑别谤别鈥檚 .

Your business is a 鈥榮mall鈥� enterprise if it has no more than 50 staff and either an annual turnover or balance sheet total of less than 鈧�10 million.

Your business is a 鈥榤edium sized鈥� enterprise if it has no more than 250 staff and either an annual turnover of less than 鈧�50 million or a balance sheet total of less than 鈧�43 million.

Further information

Updates to this page

Published 22 April 2014

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