In most cases, the ‘actual provision’ means the provision made between the affected persons (TIOPA 2010, s. 149(1) and 147(1)).

However, exceptions to this rule apply:

(1)where the transfer pricing rules apply in accordance with TIOPA 2010, s. 205(2)–(4) (oil-related ring-fence trades; see ¶798-625), in which case the actual provision is the provision made by a person (P) between the oil-related ring-fence trade and other activities carried on by P; or

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