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Finance Act 2012

Part 2: Amendments of TIOPA 2010

253.Paragraphs 2 to 6 make changes to the transfer pricing rules contained in the Taxation (International and Other Provisions) Act (TIOPA) 2010 including changes to the exemption from the requirement to calculate profits and losses of a potentially advantaged person in accordance with arm’s length principles where that person is a small or medium sized enterprise for a chargeable period.

254.Paragraph 4 inserts a new section 167A to TIOPA 2010.

255.New section 167A provides an exception to the general exemption from transfer pricing requirements for a company that is a small enterprise in the chargeable period.  This exception applies where the Commissioners for Her Majesty’s Revenue and Customs have issued a transfer pricing notice to the company.  Such a notice may relate only to provisions affecting the calculation of relevant IP profits under part 8A of CTA 2010.  A medium sized enterprise can already be required to use arm’s length principles in respect of any provision where a notice to that effect is issued under section 168 TIOPA.

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