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Article 58 - Transfer Pricing Appeals

When the question in dispute on any appeal within Article 135 is or involves a determination of whether this Part has effect as respect any conditions made or imposed between any two Persons and the question relates to any conditions made or imposed between two Persons each of whom is within the charge to tax under these Regulations in respect of profits arising from the relevant activities, then—

(a) each of the Persons as between whom the actual conditions were made or imposed shall be entitled to appear and be heard by The Regulatory Tribunal, or to make representations to them in writing;
(b) The Regulatory Tribunal shall determine that question separately from any other questions in those proceedings; and
(c) their determination on that question shall have effect as if made on an appeal to which each of those Persons was a party.
Amended (as from 18th June 2014)