7(1)Adjustments must be made so as to counteract the tax advantages that would (ignoring this Schedule) arise from profit fragmentation arrangements.
(2)The adjustments—
(a)must relate to the expenses, income, profits or losses of the resident party for the tax period in which value is transferred as a result of the material provision,
(b)must be based on what the value transferred would have been if it had resulted from a provision made or imposed as between independent parties acting at arm’s length, and
(c)must be just and reasonable.
(3)References in this paragraph to “the resident party” are references to the resident party at the time at which the material provision is made or imposed.