150 Transactions between members of a multinational group: differences with accounting for tax
Finance (No 2) Act 2023 (2023 c 30) | Legislation

150  Transactions between members of a multinational group: differences with accounting for tax

(1)     This section applies if—

(a)     a transaction between two members of a multinational group located in different territories is not recorded in the same amount, or is not recorded on an arm's length basis (or is not recorded at all), in the underlying profits accounts of both of those members, and

(b)     there is a permanent difference in respect of the transaction in relation to one or both of those members as a result of adjustments to the taxable income of the member made in connection with transfer pricing.

(2)     Subsection (3) applies if—

(a)     for each member there is a permanent difference in respect of the

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