Taxes Consolidation Act 1997 section 453

Transactions between associated persons

Section 453 was an anti-avoidance rule for manufacturing relief that recomputed the price of transactions between associated parties on an arm's length basis where artificial pricing would otherwise have inflated the relief claim.

  • Applied where a company claiming manufacturing relief bought from, or sold goods to, an associated person.
  • If the claimant bought at less than an arm's length price, the profits of both parties were recomputed as if the arm's length price had been paid.
  • If the claimant sold at more than an arm's length price, the profits of both parties were recomputed as if the arm's length price had been received.
  • The inspector could demand information to verify the position; the section was deleted by the Finance Act 2012.

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