This guidance applies to worldwide group periods of account ending before or straddling 1 April 2017.

TIOPA10/PT4

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

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