In the context of the Patent Box there is a risk of UK taxpayers shifting profits from one entity (the advantaged person) to another entity (the disadvantaged person) who is a Patent Box claimant. The shifted profit benefits from the differential between the normal CT rate and the beneficial 10% rate.
However, there is an exemption from transfer pricing rules for the vast majority of transactions carried out by businesses that are EU small or medium enterprises. There are some exceptions to this in TIOPA10/S167 and S168. S168 can require a medium sized enterprise to use arm's length principles on receipt of a notice from HMRC.