SolvedOT21130 | Corporation Tax Ring Fence: Transfer pricing: Corresponding adjustments
From HM Revenue & Customs · Oil Taxation Manual
Where an adjustment to ring fence profits falls to be made and the other party is a UK company, that company can claim a corresponding adjustment in its computations, by virtue of TIOPA10\S174.
The same principle applies if the adjustment is made within a single company under TIOPA10\S205 by virtue of TIOPA10\S147.