[INTM412130] Transfer pricing: legislation: rules: Compensating adjustments
Compensating adjustments associated with UK transfer pricing adjustments
Where a transfer pricing adjustment has been made to one party to an actual provision another party, who is not a potentially advantaged party (see INTM412020), may make a claim under TIOPA10/S174 to adjust their taxable profits if the relevant criteria are met.
The criteria are:
•Only one of the parties to the provision is an advantaged person in respect of that provision; and
•The other affected person is within the charge to income or corporation tax in respect of the relevant profits (and thus is a ‘disadvantaged person’); and