Commentary on Sections Overview Overview Section 508: Provision not at arm’s length: exclusion of arrangements from sections 503 to 507
1400.This section excludes arrangements from sections 503 to 507 where the parties are connected persons within the transfer pricing legislation in Schedule 28AA of ICTA, the arrangements are not at arm’s length and the recipient of the alternative finance return is not subject to income or corporation tax or a similar non-United Kingdom tax. It is based on section 52(1) to (3) of FA 2005.
1401.In subsection (2)(c)(ii) “an amount representing relevant return” covers back to back arrangements where there is an intermediary between the two parties to the arrangements.