PART 3

Income tax and corporation tax

Transfer pricing

Transfer pricing: application of OECD principles
75
1
In section 164(4) of TIOPA 2010 (Part to be interpreted in accordance with OECD principles)—
a
in paragraph (a) after “2010” insert “ as revised by the report, Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports, published by the OECD on 5 October 2015 ”, and
b
in the words after paragraph (b)—
i
for “such material” substitute “ material which is ”, and
ii
for “as may be so designated” substitute “ and which is designated for the time being by order made by the Treasury ”.
2
In section 357GE(1) of CTA 2010 (other interpretation), in the definition of “the OECD transfer pricing guidelines”, for the words from “means” to the end substitute “ has the same meaning as “the transfer pricing guidelines” in section 164 of TIOPA 2010 ”.
3
The amendments made by subsection (1) have effect (in relation to provision made or imposed at any time)—
a
for corporation tax purposes, in relation to accounting periods beginning on or after 1 April 2016, and
b
for income tax purposes, in relation to the tax year 2016-17 and subsequent tax years.
4
The amendment made by subsection (2) has effect in relation to accounting periods beginning on or after 1 April 2016.