The transfer pricing rules only apply where there is a provision between two parties that meet the participation test as described in B4.124 and the actual provision:
- Ìý
•ÌýÌýÌýÌý differs from one that would have been made between independent enterprises (in other words, the arm's length provision), and
- Ìý
•ÌýÌýÌýÌý creates a potential UK tax advantage for one or both of those persons
In such situations, the profits or losses of
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