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Taxation (International and Other Provisions) Act 2010

Taxation (International and Other Provisions) Act 2010

2010 CHAPTER 8

Commentary on Sections

Part 4: Transfer pricing

Chapter 8: Supplementary provisions and interpretation of Part
Section 210: The requirement for the Commissioners’ sanction

417.This section applies certain rules where a transfer-pricing determination requires the Commissioners’ sanction. It is based on section 110(1) to (3) of FA 1998.

418.If a transfer-pricing determination requires the Commissioners’ sanction, the determination will be one made for the purposes of a notice or matter mentioned in section 208(3). This section applies when the notice, or notice of the matter, is given. If the determination (so far as relating to the notice or matter) has not been approved by the Commissioners or if the determination has been approved but the taxpayer is not informed that approval has been given, the notice or matter has the effect it would have if it had been prepared without taking account of the determination.

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