Transfer Pricing - SME Exemption

Transfer Pricing - SME Exemption

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I have been searching for a list of double tax treaties which HMRC regard as containing an appropriate non-discrimination article, for SME transfer pricing exemption purposes.

All I can find is INTM 412090 which provides a list of countries as at  "1 April 2004 except where stated otherwise".

Is that the most up to date list?

Thanks in advance for any replies!

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By Exector
02nd Feb 2015 11:54

SFAIA it is

but if you note the date comments within the list and INTM412070, it is at least as at 1 April 2011, but the sensible thing would be to look at the specific UK DTA with the state involved & check the existence & wording of any non-D Article (usually around article 24). If no or not full DTA, no non-D Article or qualified, then you know the score.

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