Article 18 - Adjustments in Respect of Intra-group Financing Arrangements

Paragraph B of this Article shall apply where a Constituent Entity located in the Kingdom which is a Low-Tax Constituent Entity has incurred any expense related to an Intra-group Financing Arrangement with a High-Tax Counterparty.

For the purposes of determining the Net Constituent Entity Income or Loss for a Fiscal Year, the Constituent Entities located in the Kingdom shall exclude any expense attributable to an Intra-group Financing Arrangement that can reasonably be expected over the duration of the arrangement to increase the amount of expenses taken into account in determining the Net Constituent Entity Income or Loss without resulting in a commensurate increase in the Taxable Profit or Loss of the High-Tax Counterparty.