{
  "url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/schedule-A1/paragraph-2",
  "json_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/schedule-A1/paragraph-2.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/2",
  "kind": "paragraph",
  "number": "2",
  "heading": "Conditions for being assessed",
  "text": "(1) In its application to the unassessed transfer pricing profits which a company has for one or more accounting periods as a corporate partner of a partnership in relation to a return period by virtue of paragraph 1, Chapter 2 of this Part of this Act has effect as if—\n(a) references to the other party were to the other person mentioned in paragraph 1(1)(c);\n(b) the reference in section 217D(1) to the company were a reference to the partnership;\n(c) where the partnership has more than one relevant corporate partner in relation to the return period, for section 217D(2) there were substituted—\n“(2) “The underlying corporation tax amount” is the sum of the amounts determined in relation to each relevant corporate partner by multiplying the amount of the relevant corporate partner’s unassessed transfer pricing profits by the underlying corporation tax rate.”;\n(d) the reference in section 217D(3) to relevant tax charged (in any period) on profits that correspond to the unassessed transfer pricing profits were to the relevant corporate partners’ proportion of relevant tax charged (in any period) on profits that correspond to the partnership’s unassessed transfer pricing profits within the meaning of paragraph 1(3) of this Schedule.\n(2) In sub-paragraph (1)(d) “the relevant corporate partners’ proportion” means the proportion that—\n(a) where the partnership has one relevant corporate partner, the relevant corporate partner’s unassessed transfer pricing profits, or\n(b) where the partnership has more than one relevant corporate partner, the sum of each relevant corporate partner’s unassessed transfer pricing profits,\nbears to the partnership’s unassessed transfer pricing profits within the meaning of paragraph 1(3) of this Schedule.",
  "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/2",
    "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."
}