(1) In this section -
'Article 9(1) of the OECD Model Tax Convention' means the provisions which, at the date of the passing of the Finance Act 2019, were contained in Article 9(1) of the Model Tax Convention on Income and Capital published by the OECD;
'OECD' means the Organisation for Economic Cooperation and Development;
'transfer pricing guidelines' means the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations published by the OECD on 20 January 2022 supplemented by such additional guidance, published by the OECD on or after the date of passing of the Finance Act 2022, as may be designated by the Minister for Finance for the purposes of this Part by order made under subsection (3).
(2) For the purpose of computing profits or gains or losses chargeable to tax, this Part shall be construed to ensure, as far as practicable, consistency between -
(a) the effect which is to be given to section 835C, and
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