As part of the Finance Bill 2017, which includes measures proposed in the 2017/2018 Budget ({News-2017-04-06/P/3- previous coverage}), a new section 18A is inserted in the Income Tax Act that essentially introduces transfer pricing rules for transactions between resident related parties when one is operating in a preferential tax regime and the other is not. In particular, section 18A provides that where a resident entity operating in a preferential tax regime carries on business with a rela…