INTM432070 - TIOPA10 Part 4: how it works - Joint ventures

The control rules at INTM432060 include provisions which deem a 40% participant in a joint venture to control that joint venture. A joint venture, for these purposes, is a company or partnership which is controlled by two persons, each of whom has at least a 40% interest in the venture. This measure is intended to address arrangements where participants in a joint venture are able to use non-arm's length prices to shift profit overseas for their mutual benefit. However, the rules only apply to transactions between at least one of the joint venture parties and the joint venture itself, not between the two joint venture parties themselves (unless of course they are otherwise under common control within the definition of TIOPA10/S157 onwards).