In the great majority of cases, the ‘affected persons’ are the persons between whom the provision has been made or imposed (TIOPA 2010, s. 149(1) and 147(1)). The one exception to this is 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 affected persons are the oil-related ring-fence trade carried on by a person (A) and the other activities carried on by A (TIOPA 2010, s. 149(2)).

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