As explained at ¶226-510, new statutory principles were enacted in 2008 to govern the tax treatment of certain stock transactions. Some of the 2008 provisions potentially overlap with the transfer pricing rules now in TIOPA 2010, Pt. 4 (see ¶226-850).

Exception from open market valuation rule where certain transfer pricing provisions apply

The transfer pricing legislation broadly takes precedence over the rules in ITTOIA 2005, s. 172D (disposals not made in the course of trade: see ¶226-520) and in s. 172E (acquisitions not made in the course of trade: see ¶226-530) (per s. 172F).

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