# Taxation (International and Other Provisions) Act 2010, Paragraph 8: No postponement except before assessment is finalised for tax on same profits


(1) Section 217K applies where a designated officer has assessed the unassessed transfer pricing profits of all of the relevant corporate partners of a partnership in relation to a return period under paragraph 5 or paragraph 7(5) as it applies where a designated officer has assessed a company’s unassessed transfer pricing profits under section 217H or section 217J(5) but as if—
(a) references to the company were to the representative partner;
(b) where the partnership has more than one relevant corporate partner in relation to the return period—
(i) in subsection (2)(a) after “determination” there were inserted “in relation to each assessment”;
(ii) references to the assessment being finalised were to all of the assessments being finalised;
(iii) the reference in subsection (3)(b)(i) to the assessment were to the assessments;
(iv) the references in subsection (3)(b)(ii) and (iii) to an appeal against the assessment were to all appeals against the assessments;
(c) references to the other party were to the other person mentioned in paragraph 1(1)(c);
(d) the reference in subsection (3)(b) to section 217M(2) were to paragraph 10(3);
(e) the reference in subsection (9)(b)to relevant tax charged (in any period) on profits that correspond to the unassessed transfer pricing profits were to the relevant corporate partner’s share 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).
(2) In sub-paragraph (1)(e) “the relevant corporate partner’s share” means the share of the partnership’s profits or losses calculated under section 1259 of CTA 2009 for all of the relevant accounting periods mentioned in paragraph 1(1)(e) that is brought into account in calculating the relevant corporate partner’s profit or loss for any accounting period for corporation tax purposes.

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Source: https://www.legislation.gov.uk/ukpga/2010/8/schedule/A1/paragraph/8 (the official version)
Page: https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/schedule-A1/paragraph-8
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.

