[INTM413060] Transfer pricing: the main thin capitalisation legislation: Transaction or series of transactions
What is meant by ‘provision’?
The basic precondition in TIOPA10/S147(1)(d) permits an adjustment where the actual provision differs from the arm's length provision. TIOPA10/S147 (7) defines provision as being a transaction or series of transactions. These terms are defined in TIOPA10/S150 (previously SCH28AA/PARA3).
S150(1) says that, for this Part of TIOPA10, 'transaction'
includes arrangements, understandings and mutual practices (whether or not they are, or are intended to be, legally enforceable),
and a series of transactions is defined at S150(2) as
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