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Change 1
As published
75 Transfer pricing: application of OECD principles
(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.
Your change, as a redline
75 Transfer pricing: application of OECD principles
(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.
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