Commentary

B2.207A Transactions not carried out on commercial terms

Business tax
Business tax | Commentary

B2.207A Transactions not carried out on commercial terms

Business tax | Commentary

B2.207A Transactions not carried out on commercial terms

Transfer pricing

Transfer pricing is covered in detail in Division B4.1. Broadly, the UK transfer pricing rules may require the adjustment of trading profits or losses in a tax return where:

  1.  

    •     a provision exists between two or more affected persons, by means of a transaction or series of transactions, which is not carried out on an arm's length basis; and

  2.  

    •     that provision creates a potential UK tax advantage for one or more of those persons

For example, services may be provided by one group company to another, without a sufficient level

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