Commentary

D7.918A Transfer pricing: sales of oil or gas

Corporate tax
Corporate tax | Commentary

D7.918A Transfer pricing: sales of oil or gas

Corporate tax | Commentary

D7.918A Transfer pricing: sales of oil or gas

Additional rules apply where a buyer of oil or gas, and companies 'linked' with that buyer, have an interest of 20% or more in a company which is producing that oil or gas, whether or not the producer is the seller1.

In such a case, where a provision is made or imposed in relation to the terms of that oil sale, the transfer pricing rules apply as if the buyer, the producer and, if different, the seller were all under common control2. Note the transfer pricing rules will only apply in this situation where the effect of their application is

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