All companies within the charge to corporation tax are subject to the transfer pricing provisions of TIOPA 2010, Pt. 4 (see ¶773-000ff.). If a company sells goods or services at under-value to an associate, or purchases goods or services at over-value from an associate, the transactions shall be treated for corporation tax purposes as taking place at an arm’s length price. These provisions apply to oil companies, but with particular adaptations which were originally introduced in 1975 (see TIOPA 2010, s. 205).

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