Paragraph 3 Preliminary noticesF1

(1)

Where a designated officer considers that a company has unassessed transfer pricing profits for one or more accounting periods as a corporate partner of a partnership in relation to a return period by virtue of paragraph 1, a designated officer may issue a preliminary notice to the representative partner.

(2)

A preliminary notice issued under this paragraph must—

(a)

set out the officer’s best judgement of the amount of the partnership’s unassessed transfer pricing profits (within the meaning of paragraph 1(3));

(b)

state the return period to which the partnership’s unassessed transfer pricing profits relate;

(c)

set out the officer’s best judgement of the amount of the unassessed transfer pricing profits of all of the relevant corporate partners;

(d)

state the accounting periods to which the unassessed transfer pricing profits of all of the relevant corporate partners relate;

(e)

set out the basis on which the officer considers that the conditions mentioned in section 217C(1) are met.

(3)

A preliminary notice under this paragraph may not be issued in respect of a return period more than 4 years after the end of that period.

(4)

In this Part of this Schedule, the “representative partner” means the partner who made and delivered the partnership return to which the unassessed transfer pricing profits relate or that partner’s successor within the meaning of TMA 1970 (see section 12AA(11) and (12) of that Act).

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)