Part 4Transfer pricing

CHAPTER 4Position, if only one affected person potentially advantaged, of other affected person

Alternative way of claiming if a security is involved

183Giving effect to section 182 claims

1

A section 182 claim is not a claim within paragraph 57 or 58 of Schedule 18 to FA 1998 (company tax returns, assessments and related matters).

2

Accordingly, paragraph 59 of that Schedule (application of Schedule 1A to TMA 1970) has effect in relation to a section 182 claim.

3

If—

a

a section 182 claim is made before a calculation within section 176(1) has been made,

b

such a calculation is subsequently made, and

c

the claim is not consistent with the calculation,

the affected persons are to be treated as if (instead of the claim actually made) a claim had been made that was consistent with the calculation.

4

All such adjustments are to be made (including by the making of assessments) as are required to give effect to subsection (3).

5

Subsection (4) has effect despite any limit on the time within which any adjustment may be made.