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HMRC internal manual

Oil Taxation Manual

Corporation Tax Ring Fence: Transfer pricing: Corresponding adjustments

Where an adjustment to ring fence profits falls to be made and the other party is a UK company, that company can claim a corresponding adjustment in its computations, by virtue of TIOPA10\S174 (formerly ICTA88\Sch28AA\para6).

The same principle applies if the adjustment is made within a single company under TIOPA10\S205 by virtue of TIOPA10\S147.