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Home / Simons-Taxes /Business tax /Part B4 Transfer pricing and profit fragmentation /Division B4.1 Transfer pricing /Types of transactions and arm's length pricing / B4.140 Transfer pricing—transactions and structures

B4.140 Transfer pricing—transactions and structures

Business tax

B4.140 Transfer pricing—transactions and structures

Within multinational enterprises (MNE) there are many different ways of structuring their operations and transactions and in a transfer pricing review these structures and transactions would be reviewed as part of the comparability and functional analysis (see B4.131) to establish what each entity does, what risk they bear and whether

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D6.503 International movement of capital—reportable transactions and events

I4.265 Lifetime transfers reported late

I9.421 Situs of simple contract debts for IHT

B3.340A Hire purchase of plant and machinery and similar contracts

B2.218 Surplus business accommodation

I3.367 Fall in value relief—changes in interests in land

A4.214 Claims following further assessments—income tax and capital gains tax

C1.106A Annual exempt amount

I4.562 Sales and mortgages of reversionary interests

C2.1168 Property rich collective investment vehicles—ceasing to meet the exemption election requirements

C3.1705 Non-qualifying tax years, and disposals of a main home under NRCGT

E6.324H Nominated income and gains and the ordering rules

E4.1167 Payments made after leaving and after issue of form P45

I5.221 Lifetime termination of QIIP—general

E7.234 Other types of lifetime benefit lump sum

D6.711 Liquidation—capital gains implications

E3.192 CGT loss relief on disposal of EIS shares

D6.233 Rights issue—sale of rights nil paid

C3.1706 PPR relief where there is job-related accommodation

D1.1422 Calculating NGIE and ANGIE