Updates to HMRC's International Manual

Within the past month HMRC has released a number of updates to its International Manual.

Some of the changes update legislative references due to the introduction of TIOPA 2010 and Statement of Practice 02/10 on Advance Pricing Agreements; other changes consolidate guidance provided elsewhere on HMRC’s website.

However in among the changes are some interesting insights into HMRC working practices and ‘customer friendly’ initiatives.

This article focuses on the changes in respect of:

• real time working of transfer pricing issues and APAs;
• APAs;
• cost contribution agreements; and
• share options.

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