{
  "url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/schedule-A1/paragraph-10",
  "json_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/schedule-A1/paragraph-10.json",
  "legislation": "ukpga/2010/8",
  "legislation_title": "Taxation (International and Other Provisions) Act 2010",
  "legislation_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010",
  "path": "schedule/A1/paragraph/10",
  "kind": "paragraph",
  "number": "10",
  "heading": "Appeal against assessment",
  "text": "(1) An appeal against the assessment of the unassessed transfer pricing profits of a relevant corporate partner of a partnership in relation to a return period under this Schedule may only be made—\n(a) by the representative partner, and\n(b) where the partnership has more than one relevant corporate partner in relation to the return period, by the representative partner appealing at the same time against the assessments of the unassessed transfer pricing profits of all of the relevant corporate partners.\n(2) The representative partner in the partnership may only bring an appeal against such an assessment where—\n(a) all of the relevant corporate partners have paid (in full) the corporation tax charged on the profits assessed other than any amount the payment of which has been postponed in accordance with paragraph 8, and\n(b) the period for amendments has ended.\n(3) Notice of an appeal must be given before the end of the period of 30 days beginning with—\n(a) the end of the period for amendments, or\n(b) in a case where paragraph 6(4) applies, the day after the day on which the period for amendments ends,\n(and accordingly paragraph 48(2)(b) of Schedule 18 to FA 1998 does not apply).\n(4) Sub-paragraphs (5) and (6) apply where, on an appeal against an assessment of a relevant corporate partner’s unassessed transfer pricing profits, the tribunal decides that the company is overcharged by the assessment as a result of one or more of the conditions mentioned in section 217C(1) not applying in respect of unassessed transfer pricing profits so assessed.\n(5) The tribunal may, in addition to any other powers exercisable by the tribunal in those circumstances, reduce the tax charged on the amount assessed to assess the unassessed transfer pricing profits to corporation tax not at the UTPP rate.\n(6) But where the partnership has more than one relevant corporate partner in relation to the return period the tribunal may only exercise the power in sub-paragraph (5) if the tribunal exercises the power on the appeal against the assessment of the unassessed transfer pricing profits of each relevant corporate partner.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Sch. A1 inserted (for accounting periods beginning on or after 1.1.2026) by Finance Act 2026 (c. 11), s. 46(2), Sch. 5 para. 1(2)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2010/8/schedule/A1/paragraph/10",
    "retrieved_at": "2026-10-29T09:10:17.008829+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}