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Paragraph 14 Modifications to Parts 1 to 3 of this ScheduleF1

(1)

Paragraph 1 (unassessed transfer pricing profits) has effect as if—

(a)

references to relevant accounting period, one or more relevant accounting periods, one or more of those relevant accounting periods and each of the relevant accounting periods mentioned in sub-paragraph (1)(e) were to the underwriting year;

(b)

the references in sub-paragraph (1)(a) and (5)(b) to partner were to corporate member;

(c)

in sub-paragraph (2) after “brought into account”, in the first place it occurs, there were inserted “during the period for amendments (see paragraph 6)”;

(d)

sub-paragraph (5)(a) (and the “accordingly” at the start of sub-paragraph (5)(b)) and sub-paragraphs (6)(a), (c) and (d) were omitted.

(2)

Paragraph 3 (preliminary notices) has effect as if sub-paragraph (4) were omitted.

(3)

Paragraph 5 (assessment) has effect as if sub-paragraph (5)(b) were omitted.

(4)

Paragraph 6 (amendment of return) has effect as if—

(a)

after sub-paragraph (2) there were inserted—

“(2A)

Where the syndicate return is amended under sub-paragraph (2), a designated officer must, by notice to each of the relevant corporate members, amend the corporate member’s company tax return so as to give effect to the amendment of the syndicate return.”;

(b)

in sub-paragraph (6), the reference to section 12AD(3) of TMA 1970 were to paragraph 31(3) of Schedule 18 to FA 1998.

(5)

Paragraph 8 (no postponement except before assessment is finalised for tax on same profits) has effect as if the reference in sub-paragraph (2) to all of the relevant accounting periods mentioned in paragraph 1(1)(e) were to the underwriting year.

(6)

Paragraph 9 has effect as if—

(a)

the reference in sub-paragraph (2) to section 28B of TMA 1970 were to paragraph 32 of Schedule 18 to FA 1998;

(b)

the reference in sub-paragraph (3) to section 28B of the TMA 1970 were to paragraph 33 of Schedule 18 to FA 1998;

(c)

for sub-paragraph (4) there were substituted—

“(4)

Where a relevant closure notice issued after the end of the period for amendments amends the syndicate return to more fully reflect the transfer pricing requirement to which the unassessed transfer pricing profits relate, the amendment may not be given effect—

(a)

by amending any relevant corporate member’s tax return in a closure notice, or

(b)

otherwise by an assessment to corporation tax on any of the relevant corporate members.”

Annotations

Textual amendments

F1

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)