Usually, when companies are in a Tax Group, they don’t have to worry about transfer pricing rules for transactions between them. That’s because, in the group’s financial reports, these transactions get cancelled out.

But, if a company in the group has losses from before they joined the group (pre-Grouping Tax Losses), or in certain other special situations where they need to figure out the taxes for one company in the group separately, then they have to follow the transfer pricing rules. They also have to keep good records of these transactions.