Section GB 2 — Income Tax Act 2007: Arrangements involving transfer pricing

GB 2 Arrangements involving transfer pricing When this section applies (1) This section applies in relation to a person if an arrangement has a purpose or effect of defeating the intent and application of— (a) section GC 7 (Excess amount payable by person): (b) section GC 8 (Insufficient amount receivable by person): (c) section GC 9 (Compensating arrangement: person paying less than arm’s length amount): (d) section GC 10 (Compensating arrangement: person receiving more than arm’s length amount). Possible examples (2) Without limiting the generality of subsection (1), the following collateral arrangements may result in that purpose or effect: (a) a collateral arrangement with an associated person who is a non-resident: (b) a market-sharing arrangement: (c) an arrangement not to enter a market: (d) a back-to-back supply arrangement: (e) an income-sharing arrangement. Application of sections GC 7 to GC 10 (3) Section GC 7 , GC 8 , GC 9 , or GC 10 , as applicable, applies to require the substitution of an arm’s length amount of consideration, despite section GC 6(2) and (3) (Purpose of rules and nature of arrangements). Defined in this Act: arrangement , associated person , non-resident , Compare: 2004 No 35 s GC 1