Corporation tax: Transfer pricing | Practical Law

Corporation tax: Transfer pricing | Practical Law

The Special Commissioners have held that, for transfer pricing purposes, the making of loans amounts to the giving of business facilities; a notional rate of interest can therefore be imputed on an interest-free loan made by a company to its foreign affiliate.

Corporation tax: Transfer pricing

Practical Law UK Legal Update 2-100-2455 (Approx. 2 pages)

Corporation tax: Transfer pricing

Published on 01 Oct 1996United Kingdom
The Special Commissioners have held that, for transfer pricing purposes, the making of loans amounts to the giving of business facilities; a notional rate of interest can therefore be imputed on an interest-free loan made by a company to its foreign affiliate.