Acting together

GARETH GREEN explains the proposed transfer pricing rules for persons 'acting together'.

FOR TAXPAYERS AND advisers still trying to get to grips with last year's extension of transfer pricing rules to UK-UK transactions the last thing they needed was some further new rules to be puzzled out and perhaps they have been given some breathing space by the forthcoming election. Since this article was written the amendments to the transfer pricing rules were removed from the Finance Bill 2005 together with most other controversial innovations. It is however expected that these proposed changes will be reintroduced following the general election and most likely will remain back-dated to 4 March 2005. The rest of the article therefore remains as previously written.

These latest (proposed) rules have largely been billed as relating to private equity investments and certainly this is the primary target of the...