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HMRC internal manual

Oil Taxation Manual

Non-residents working on the UK continental shelf: transfer pricing: interaction with double taxation treaties

If there is a treaty in force between the UK and the country of residence of the overseas affiliate, it will invariably include an Associated Enterprises Article. In general, conditions applying in commercial or financial arrangements between independent enterprises may be substituted for an inter-affiliate transaction conducted on some other basis if profits which should have accrued to the UK have not done so because the wrong transfer-price was used.

This means that TIOPA2010\S147+ is consistent with, and not overridden, even if a double taxation treaty is in force with the other country.