Paragraph 3 Provision made or imposed between RPD activities and other activities of the same company
United Kingdom
Chapters 1 and 3 to 6 (read in accordance with Chapters 2 and 8) of Part 4 of TIOPA 2010 (transfer pricing) apply to provision made or imposed as between an RP developer’s RPD activities and other activities carried on by it as if—
(a)
those activities were carried on by two different persons,
(b)
the provision were made or imposed between those persons by means of a transaction, and
(c)
the two persons were both controlled by the same person at the time of the making or imposition of the provision.