Other tax rules

Transfer pricing

See INTM566010 for guidance on thin capitalisation issues in securitisation structures, and INTM430000 for more on transfer pricing rules generally. A securitisation company within the regulations calculates its profit in accordance with Regulation 14 and not on the basis of its profits. It cannot self-assess an adjustment to those profits under TIOPA10/Part 4, nor can such an adjustment be sought by HMRC.

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