Part G
Avoidance and non-market transactions
Market value substituted
GC 7Excess amount payable by person
If the amount of consideration payable by a person (the taxpayer) under a transfer pricing arrangement is more than an arm’s length amount, an amount equal to the arm’s length amount is treated as the amount payable by the taxpayer for the purposes of the calculation of their income tax liability for a tax year.
Compare
- 2004 No 35 s GD 13(3)