{
  "url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/schedule-A1/paragraph-5",
  "json_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/schedule-A1/paragraph-5.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/5",
  "kind": "paragraph",
  "number": "5",
  "heading": "Assessment",
  "text": "(1) This paragraph applies where—\n(a) a designated officer has issued a preliminary notice to the representative partner under paragraph 3 in relation to a return period of the partnership, and\n(b) a designated officer has considered any representations made by the representative partner in accordance with section 217G (as applied by paragraph 4).\n(2) A designated officer may assess the unassessed transfer pricing profits of all of the relevant corporate partners of the partnership in relation to the return period to corporation tax at the UTPP rate.\n(3) For the purposes of sub-paragraph (2), a designated officer assesses the unassessed transfer pricing profits of all of the relevant corporate partners of the partnership by—\n(a) where the partnership has one relevant corporate partner in relation to the return period, assessing the relevant corporate partner on the relevant corporate partner’s unassessed transfer pricing profits for the accounting period or periods stated in the preliminary notice;\n(b) where the partnership has more than one relevant corporate partner in relation to the return period, assessing each relevant corporate partner on the relevant corporate partner’s unassessed transfer pricing for the accounting periods stated in the preliminary notice, on the same day.\n(4) Notices of any assessments under this paragraph issued to a relevant corporate partner must also be issued to the representative partner.\n(5) Subsections (3) to (5) of section 217H have effect in relation to an assessment under this paragraph as they have effect in relation to an assessment under section 217H but as if—\n(a) the reference in subsection (4) to the other party were to the other person mentioned in paragraph 1(1)(c),\n(b) references to paragraph 33 of Schedule 18 to FA 1998 were to section 28B of TMA 1970, and\n(c) the reference in subsection (5) to the company tax return for the accounting period mentioned in subsection (1)(a) were to the partnership return for the return period mentioned in sub-paragraph (1)(a).",
  "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/5",
    "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."
}