Overview Section 564H: Provision not at arm’s length: exclusion of arrangements from sections 564C to 564G
766.This section excludes arrangements from sections 564C to 564G where the parties are connected persons within the transfer pricing legislation in Part 4 of this Act, the arrangements are not at arm’s length and the recipient of the alternative finance return is not subject to income tax or corporation tax or a similar non-United Kingdom tax. It is based on section 52(1) to (3) of FA 2005. The corresponding rule for corporation tax is section 508 of CTA 2009.