Related Commentary  Related HMRC Manuals

164(1)  This Part is to be read in such manner as best secures consistency between–

(a)the effect given to sections 147(1)(a), (b) and (d) and (2) to (6), 148 and 151(2), and

(b)the effect which, in accordance with the transfer pricing guidelines, is to be given, in cases where double taxation arrangements incorporate the whole or any part of the OECD model, to so much of the arrangements as does so.

164(2)  Subsection (1) has effect subject to–

section 147(1)(c) and (7) (oil-related provision to which Part does not apply),

sections 205 and 206 (rules for oil-related ring-fence trades),

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