(1) Subject to this Part, this section applies to any arrangement -
(a) involving the supply and acquisition of goods, services, money, assets (including intangible assets) or anything else of commercial value,
(b) where, at the time of the supply and acquisition, the person making the supply (in this Part referred to as the 'supplier') and the person making the acquisition (in this Part referred to as the 'acquirer') are associated, and
(c) the profits or gains or losses arising from the relevant activities are within the charge to tax in the case of either the supplier or the acquirer or both.
(a) If the amount of the consideration payable (in this Part referred to as the 'actual consideration payable') for an acquisition under any arrangement to which this section applies exceeds the arm's length amount, then the profits or gains or losses of the acquirer that are chargeable to tax shall be computed as if the arm's length amount were payable instead of the actual consideration p
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