Taxation (International and Other Provisions) Act 2010 section 150

"Transaction" and "series of transactions"

Section 150 defines the terms "transaction" and "series of transactions" for the purposes of the transfer pricing rules, ensuring these concepts are interpreted broadly enough to capture a wide range of arrangements between connected parties.

• A "transaction" is defined very broadly and includes not only formal legal agreements but also informal arrangements, understandings, and mutual practices, whether or not they are legally enforceable.
• A "series of transactions" covers multiple transactions carried out under the same overarching arrangement, regardless of whether they occur sequentially or simultaneously.
• A series of transactions can still be treated as provision made between two persons even if those two persons are not both parties to any single transaction in the series, or are not parties to the underlying arrangement.
• The term "arrangement" itself is given the widest possible meaning, covering any scheme or arrangement of any kind, whether or not it is intended to be legally enforceable.