OT20330 - Corporation Tax General

Transfer Pricing. Introduction.

For pre CTSA periods the general transfer pricing rules were contained in ICTA88\s770 et seq. For accounting periods ending on or after 1 July 1999 these general rules were overhauled and strengthened. The new rules are in ICTA88\Sch 28AA. Guidance on these new rules can be found at IM, and is not repeated here. The following paragraphs explain how the normal rules are specifically modified for oil companies, and the impact of these modified rules on cross ring fence transactions.