[INTM413040] Transfer pricing: the main thin capitalisation legislation: Summary of sections specific to thin capitalisation
Thin cap-specific legislation
The basic transfer pricing legislation, which applies to finance as much as it applies to goods and services, is discussed starting at INTM412010.
There are specific sections within TIOPA10/Part 4 that apply only to loans between two companies:
•TIOPA10/S152 requires that in the case of lending between companies, certain factors to be considered when comparing the arm's length provision with the actual provisions in TIOPA10/S147(1)(d). See INTM413100
•TIOPA10/S181 to TIOPA10/S184 sets out the conditions required for a lender to make a valid compensating adjustment claim where a disallowance has been made in the borrower's computations. See INTM413140