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Introduction

Guidance

The International Manual contains up to date guidance for HM Revenue & Customs staff on key international tax issues including practical guidance on working transfer pricing and thin capitalisation cases.

We will continue to expand and update the Manual to include guidance on new legislation and litigation which has become final.

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Acknowledgment

This manual includes quotations from two OECD publications:

• the Model Tax Convention on Income and Capital, © OECD 2010, and
• The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, © OECD 2010

The copyright owner of this material remains OECD.