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Division B4.1ÌýÌýÌýÌý Transfer pricing

For updates affecting this Division please see Part B0 Updates

Transfer pricing—UK regime

B4.120 Transfer pricing—overview

For the latest New Development, see ND.2245.

The current transfer pricing legislation is contained in TIOPA 2010, ss 146–217 and applies for corporation tax and income tax purposes. The intention of the legislation is to counter a loss of tax which may arise from non-arm's length pricing in a provision which takes place between persons that are not independent. This is done by comparing the profit or loss from the actual provision made with the profit or loss from a provision made at an arm's length price. If the arm's length provision would result in a higher taxable profit or a lower tax loss then the actual provision is replaced with the arm's length one. Any reduction in profit or increase in loss only comes about through a compensating adjustment.

There are exemptions from the transfer pricing regime with the most