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Version status: In force | Document consolidation status: Updated to reflect all known changes
Version date: 1 January 2022 - onwards
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835E. Modification of basic rules on transfer pricing for arrangements between qualifying persons

(1) For the purposes of this Part, a 'qualifying person', in relation to a chargeable period, means a person who -

(a) subject to paragraph (b) -

(i) is a supplier in relation to an arrangement and who for that chargeable period is chargeable to income tax or corporation tax under Schedule D, other than under Case I or II of Schedule D, in respect of the profits or gains or losses arising from that arrangement, or

(ii) is an acquirer in relation to an arrangement and who for that chargeable period is chargeable to income tax or corporation tax under Schedule D in respect of the profits or gains or losses arising from that arrangement,

(b) is resident in the State for the purposes of income tax for that chargeable period where the supplier or the acquirer is chargeable to income tax in respect of the profits or gains or losses arising from that arrangement, and

(c) is not a qualifying company within the meaning of section 110.

(2)

(a) For the purposes of subsection (1)(a)(i), a supplier

Comparing proposed amendment...