Taxation (International and Other Provisions) Act 2010 section 216

Meaning of "the relevant activities"

Section 216 defines "the relevant activities" for the purposes of the transfer pricing rules, identifying which of a person's activities are connected to a particular transaction or arrangement between related parties.

• The "relevant activities" are those carried on by a person in the course of which, or in connection with which, a transfer pricing provision is made or imposed between that person and another party.
• Activities that are carried on separately from the transaction in question are excluded from the definition.
• Activities undertaken for the purposes of a different part of the person's business are also excluded, even if that person is party to the arrangement.
• The effect is to ring-fence only those activities directly associated with the particular provision being examined under the transfer pricing rules.