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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 UK as well as those that are cross border), and given the different rates at which ring fence and general corporation tax are payable, transfer pricing on UK to UK transactions where one party has a ring fence trade may be more relevant than where both pay general corporation tax. Where the rules apply, the profits and losses of each of the potentially advantaged persons shall be computed for tax purposes as if an arm's length provision had been made instead of the actual provision.