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

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