Commentary

D7.918 Transfer pricing in relation to ring fence trades

Corporate tax
Corporate tax | Commentary

D7.918 Transfer pricing in relation to ring fence trades

Corporate tax | Commentary

D7.918 Transfer pricing in relation to ring fence trades

The transfer pricing rules (see Division B4.1) apply where an arrangement or a 'provision' has been made or imposed between two or more persons that differs from a provision that would have been made between independent persons and as a result of this arrangement, a potential UK tax advantage is conferred on one or more of the parties to the arrangement by virtue of either reduced chargeable profits or increased losses. The rules apply irrespective of the residence of the parties concerned (ie they can apply to transactions wholly within the

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial