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(2) A relevant person in relation to an arrangement to which section 835C(1) applies, and who is chargeable to tax in respect of the profits or gains or losses arising from the relevant activities, shall have available and, upon a request made in writing by a Revenue officer, shall provide such records as may reasonably be required for the purposes of determining whether, in relation to the arrangement, the profits or gains or losses of the person that are chargeable to tax have been computed in accordance with this Part.

gains included in a return delivered by a relevant person on or before the specified return date for the chargeable period because, by virtue of section 835C, the profits or gains or losses of a relevant person that are chargeable to tax are computed as if, instead of the actual consideration payable or receivable under an arrangement, the arm’s length amount were payable or receivable, as the case may be.

(8) Subsection (3) of section 886 shall apply to the records referred to in subsections (2) and (3) as it applies to records required by that section.

“constituent entity” , “fiscal year” and “MNE group” have the same meanings as in section 891H but, as respects the application of the definition of “MNE Group” in Article 1 of the OECD model legislation (as defined in section 891H) for the purpose of this section, that definition shall apply as if the words and (ii) is not an Excluded MNE Group” were deleted therefrom;

“constituent entity” , “fiscal year” and “MNE group” have the same meanings as in section 891H but, as respects the application of the definition of “MNE Group” in Article 1 of the OECD model legislation (as defined in section 891H) for the purpose of this section, that definition shall apply as if the words and (ii) is not an Excluded MNE Group” were deleted therefrom;

“return” and “specified return date for the chargeable period” have the same meanings as in section 959A;

(b) Where the conditions set out in paragraph (c) are met, a transfer pricing adjustment shall not be taken into account in determining whether a penalty referred to in section 1077E(5) applies to the relevant person for a chargeable period or in computing the amount of any such penalty.