INTM489600 - Diverted Profits Tax: application of Diverted Profits Tax: legislation 바카라 사이트“ Finance Act 2015 바카라 사이트“ core provisions: transaction or series of transactions

바카라 사이트śThe material provision바카라 사이트ť must be made or imposed as between C and P by means of a transaction or series of transactions. 바카라 사이트śTransaction바카라 사이트ť has the same meaning as in the transfer pricing rules at Part 4 TIOPA 2010 (see INTM412050), and includes arrangements, understandings and mutual practices (whether or not they are legally enforceable).

Similarly the meaning of a series of transactions is consistent with section 150 TIOPA and a series exists whether or not:

  • there is a transaction in the series to which both connected persons are party
  • the arrangements by which the series of transactions are entered into are between the two connected persons
  • there is a transaction in the series to which neither connected person is a party.

바카라 사이트śArrangement바카라 사이트ť means any scheme or arrangement of any kind (whether or not they are legally enforceable or intended to be so).

This wide definition means that provision may be made between C and P even if it is done so indirectly through a series of transactions some of which may involve third parties.