Related Commentary  Related CasesRelated HMRC Manuals

147(1)  For the purposes of this section “the basic pre-condition” is that–

(a)provision (“the actual provision”) has been made or imposed as between any two persons (“the affected persons”) by means of a transaction or series of transactions,

(b)the participation condition is met (see section 148),

(c)the actual provision is not within subsection (7) (oil transactions), and

(d)the actual provision differs from the provision (“the arm's length provision”) which would have been made as between independent enterprises.

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