Brief

On 10/01/2025, Her Majesty's Revenue and Customs (HMRC) issued an update regarding International Manual. The document covers international tax issues including principles of double taxation relief and introduction to double taxation agreements, as well as topics such as controlled foreign companies, non-residents trading in the UK, transfer pricing, diverted profits tax, intra-group funding, thin capitalisation, hybrids, and immunities and privileges.

Summary

International tax issues including the principles of double taxation relief and an introduction to double taxation agreements

Contents

INTM050000
Data protection

INTM100000
Introduction

INTM120000
Company residence: contents

INTM150000
Principles of Double Taxation Relief and Introduction to Double Taxation Agreements: contents

INTM160000
Double Taxation Relief: contents

INTM190000
Controlled Foreign Companies: contents

INTM260000
Non-residents trading in the UK: contents

INTM280000
Foreign permanent establishments of UK companies: contents

INTM330000
DT applications and claims in CAR Residency: contents

INTM370000
The Non-resident Landlords Scheme: contents

INTM400000
Interest and Royalty Payments: contents

INTM410000
Transfer pricing: legislation and principles: contents

INTM420000
Transfer pricing – methodology: contents

INTM440000
Transfer pricing – Types of transactions: contents

INTM441000
Transfer Pricing – Transactions and Structures – Business Structures: contents

INTM450000
Transfer pricing records: contents

INTM480000
Transfer pricing – operational guidance: contents

INTM489500
Diverted Profits Tax: contents

INTM500000
Intra-group funding: contents

INTM510000
Thin capitalisation: practical guidance: contents

INTM550000
Hybrids: contents

INTM590000
Arbitrage – legislation and principles: contents

INTM597000
Arbitrage: practical guidance: contents

INTM600000
Transfer of assets abroad: contents

INTM610000
Contents: Profit Fragmentation Rules

INTM620000
ORIP:Contents

INTM630000
Royalty Withholding: Contents

INTM650000
Distribution exemption: contents

INTM700000
International movements of capital: contents

INTM800000
Technical guidance for Swiss/UK Tax Cooperation Agreement: contents

INTM850000
Hybrid and other mismatches

INTM860000
Immunities and Privileges: Contents

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Purpose
The provided document aims to provide an in-depth understanding of international tax issues, including the principles of double taxation relief and an introduction to double taxation agreements. The objective is to educate readers on various aspects of international taxation, from company residence to transfer pricing and hybrid mismatches.

Effects on Industry
The update will have a significant impact on businesses operating globally, particularly those involved in international trade, investment, and finance. It will affect companies’ tax planning strategies, as they will need to comply with the principles of double taxation relief and double taxation agreements. The update may also lead to changes in transfer pricing methodologies and the identification of hybrid mismatches.

Relevant Stakeholders
This document is relevant to various stakeholders, including:

  • Businesses operating globally
  • Tax professionals and advisors
  • Governments and tax authorities
  • International organizations and institutions
  • Investors and financial institutions

These stakeholders will need to understand and comply with the principles outlined in the document to avoid double taxation and ensure fair taxation practices.

Next Steps
To comply with the update, businesses and tax professionals should:

  • Familiarize themselves with the principles of double taxation relief and double taxation agreements
  • Review and adjust their transfer pricing methodologies to ensure compliance with new guidelines
  • Identify potential hybrid mismatches and take steps to rectify them
  • Consult with tax authorities and advisors to ensure compliance with all relevant regulations

Any Other Relevant Information
It is essential for businesses and tax professionals to stay up-to-date with changes in international taxation laws and regulations. This document provides a comprehensive overview of key concepts, including company residence, double taxation relief, transfer pricing, and hybrid mismatches. The information provided will help stakeholders navigate the complexities of international taxation and ensure compliance with relevant regulations.

Her Majesty’s Revenue and Customs (HMRC)

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