Schedule 28AA Provision not at arm’s lengthF1F2

United Kingdom

1. Basic rule on transfer pricing etc.
2. Provision in relation to securities: determination of arm’s length provision
3. Guarantees etc
4. Principles for construing rules in accordance with OECD principles
5. Meaning of “transaction" and “series of transactions"
6. Participation in the management, control or capital of a person
7. Persons acting together in relation to financing arrangements
8. Financing arrangements: anticipatory provision
9. Advantage in relation to United Kingdom taxation
10. Exemption for dormant companies
11. Exemption for small or medium-sized enterprises
12. Additional provisions for medium-sized enterprises
13. Meaning of “small enterprise” and “medium-sized enterprise”
14. Meaning of “qualifying territory” and “non-qualifying territory”
15. Elimination of double counting
16. Application of paragraph 6 in relation to transfers of trading stock etc
17. Compensating adjustment where advantaged person is a controlled foreign company
18. Claims under paragraph 6 where paragraph 1A applies
19. Compensating adjustment for guarantor company etc where paragraph 1B applies
20. Certain interest not to be regarded as chargeable
21. Adjustment of disadvantaged person’s double taxation relief
22. Balancing payments between affected persons: no charge to, or relief from, tax
23. Securities: election to discharge tax liability instead of making balancing payments
24. Balancing payments by guarantor to issuer: no charge to, or relief from, tax
25. Guarantees: election to discharge tax liability instead of making balancing payments
26. Foreign exchange gains and losses and financial instruments
27. Special rules for sales etc. of oil
28. Transactions and deemed transactions involving oil
29. Special provision for companies carrying on ring fence trades
30. Appeals
31. Saving for the provisions relating to capital allowances and capital gains
32. General interpretation etc.