This guidance applies to worldwide group periods of account ending before or straddling 1 April 2017.
TIOPA10/S155(6)(a) provides that the debt cap is to be disregarded in applying the transfer pricing rules in TIOPA10/PT4. Accordingly the debt cap is applied after any transfer pricing adjustments have been made to a company's tax position.
TIOPA10/PT4 operates to substitute the arm's length provision for the actual provision for tax purposes where:
•one party to the provision controls the other, or both are controlled by the same person