Corporation Tax Act 2009 section 693

Bringing into account adjustments under Part 4 of TIOPA 2010

Section 693 deals with how transfer pricing adjustments under the arm's length rules are brought into the derivative contracts tax regime as credits and debits.

• Where transfer pricing rules treat an amount as profits or losses from a derivative contract, the corresponding credits or debits are brought into account just as if those profits or losses had actually arisen
• Where transfer pricing rules treat an amount as expenses incurred under a derivative contract, the corresponding debits are brought into account just as if those expenses had actually been incurred
• All credits and debits arising from transfer pricing adjustments are subject to the same rules that apply to actual derivative contract amounts
• No credit may be brought into account to the extent it corresponds to an amount that was never brought into account as a debit under these provisions