Taxation (International and Other Provisions) Act 2010
18.The Act contains provisions relating to:
double taxation relief;
transfer pricing;
advance pricing agreements;
tax arbitrage;
tax treatment of financing costs and income;
offshore funds; and
relocation of provisions of tax legislation.
19.The Act has 382 sections and 11 Schedules. The sections are arranged as follows:
Part 1: Overview
Part 2: Double taxation relief
Part 3: Double taxation relief for special withholding tax
Part 4: Transfer pricing
Part 5: Advance pricing agreements
Part 6: Tax arbitrage
Part 7: Tax treatment of financing costs and income
Part 8: Offshore funds
Part 9: Amendments to relocate provisions of tax legislation
Part 10: General provisions
20.The Schedules are:
Schedule 1: Oil activities: new Chapter 16A of Part 2 of ITTOIA 2005
Schedule 2: Alternative finance arrangements
Schedule 3: Leasing arrangements: finance leases and loans
Schedule 4: Sale and lease-back etc: new Part 12A of ITA 2007
Schedule 5: Factoring of income etc: new Chapters 5B and 5C of Part 13 of ITA 2007
Schedule 6: UK Representatives of non-UK residents
Schedule 7: Miscellaneous relocations
Schedule 8: Minor and consequential amendments
Schedule 9: Transitionals and savings etc
Schedule 10: Repeals and revocations
Schedule 11: Index of defined expressions used in Parts 2 to 8