- Y Diweddaraf sydd Ar Gael (Diwygiedig)
- Pwynt Penodol mewn Amser (01/04/2014)
- Gwreiddiol (Fel y'i Deddfwyd)
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Finance Act 2014, Cross Heading: Transfer pricing is up to date with all changes known to be in force on or before 10 October 2024. There are changes that may be brought into force at a future date. Changes that have been made appear in the content and are referenced with annotations.
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Yn ddilys o 17/07/2014
(1)Chapter 4 of Part 4 of TIOPA 2010 (transfer pricing: position of disadvantaged person) is amended as follows.
(2)In section 174 (claim by the affected person who is potentially advantaged), in subsection (3), before the entry for section 175 insert— “ section 174A (claim not allowed in some cases where the disadvantaged person is within the charge to income tax), ”.
(3)After that section insert—
A claim under section 174 may not be made if—
(a)the disadvantaged person is a person (other than a company) within the charge to income tax in respect of profits arising from the relevant activities, and
(b)the advantaged person is a company.”
(4)After section 187 insert—
(1)Subsection (2) applies if Conditions A to C in section 187 are met in circumstances where section 174A prevents a claim under section 174.
(2)The interest paid under the actual provision, so far as it exceeds ALINT, is treated for the purposes of the Income Tax Acts as a dividend paid by the company which paid the interest (and, accordingly, as a qualifying distribution).”
(5)The amendments made by this section have effect in relation to any amount arising on or after 25 October 2013, except pre-commencement interest.
(6)“Pre-commencement interest” means an amount of interest to the extent that it is, in accordance with generally accepted accounting practice, referable to a period before 25 October 2013.
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