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Taxation (International and Other Provisions) Act 2010

Type Public General Act

Publication 2010-03-18

Last updated 2026-09-11

State In force

Department Statute Law Database

Source legislation.gov.uk

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An Act to restate, with minor changes, certain enactments relating to tax; to make provision for purposes connected with the restatement of enactments by other tax law rewrite Acts; and for connected purposes.

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(5) For the purposes of this section “arrangements” include any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable).

Holdings of debt and equity in same proportions

467

(1) This section applies at any time where—

(a) persons have lent money to another person (“U”),

(b) the lenders also have shares or voting power in U,

(c) the amounts each of the lenders has lent stand in the same, or substantially the same, proportion as the shares or voting power in U that each of them has, and

(d) for the purposes of section 464 the lenders (taken together) have a 25% investment in U.

(2) The lenders are treated for the purposes of this Part as if, in relation to the loans (and anything done under or for the purposes of them), they were related parties of U at that time (so far as that would not otherwise be the case).

(3) If—

(a) some or all of the rights under the loan are transferred, and

(b) the transferred rights are held by, or for the benefit of, another person (“the transferee”) at any time,

the transferee is treated for the purposes of this Part as if, in relation to the loan (and anything done under or for the purposes of it), the transferee were a related party of U at that time (so far as that would not otherwise be the case).

(4) This applies whether or not the transferee has any shares or voting power in U.

(5) For the purposes of this section references to shares in U include shares in U that may be held as a result of the exercise of any right or power and include rights or interests in U that are of a similar character to shares.

(6) This section applies (with any necessary modifications) in relation to any other financial liability owed to, or any transaction with, U as it applies to loans made to U.

Debts with same rights where unrelated parties hold more than 50%

468

(1) This section applies if—

(a) a person (“D”) is party to a loan relationship as debtor in a period of account of a worldwide group of which it is a member,

(b) a person (“C”) who is party to the loan relationship as creditor is a related party of D at any time in that period,

(c) there are persons (“the relevant creditors”) other than C who are parties to the loan relationship, or are parties to other loan relationships entered into at the same time, as creditors but who are not related parties of D at any time in that period,

(d) at all times in that period the rights of the relevant creditors are rights in relation to at least 50% of the total amount of the money debt or debts in question, and

(e) at all times in that period C and the relevant creditors have the same rights in relation to the money debt or debts in question.

(2) D and C are treated for the purposes of this Part as if, in relation to the loan relationship concerned (and anything done under or for the purposes of it), they were not related parties of each other at any time in that period.

(3) Persons are not to be regarded as having the same rights in relation to a money debt or debts at any time if—

(a) the terms or conditions on which any of the money is lent and which are in force at that time make different provision in relation to different persons or have, or are capable of having, a different effect in relation to different persons (whether at that or any subsequent time),

(b) arrangements are in place at that time the effect of which is that, at that or any subsequent time, the rights of some persons in relation to any of the debts differ, or will or may differ, from the rights of others in relation to any of the debts, or

(c) any other circumstances exist at that time as a result of which the rights of some persons in relation to any of the debts cannot reasonably be regarded as being, in substance, the same rights as others in relation any of the debts at that or any subsequent time.

(4) For the purposes of this section—

“arrangements” include any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable),

“different persons” includes persons of a different class or description, and

“rights” includes powers.

Debt restructuring

469

(1) This section—

(a) makes provision for treating a person (“D”) who is a related party of another person (“C”) as if they were not related parties of each other but only in respect of particular liabilities or transactions, and

(b) is expressed to apply in relation to loan relationships but also applies (with any necessary modifications) in relation to any other financial liability owed to, or any transaction with, C.

(2) If—

(a) D is party to a loan relationship as debtor and C is party to the loan relationship as creditor,

(b) D subsequently becomes a related party of C in consequence of a relevant release of debt, and

(c) before D became a related party of C in consequence of the release none of the parties to the loan relationship had been related parties of each other,

D and C are treated for the purposes of this Part as if, in relation to the loan relationship (and anything done under or for the purposes of it), they were not related parties of each other at times on or after the release.

(3) There is a “relevant release of debt” at any time for the purposes of this section if—

(a) a liability to pay an amount under a person's debtor relationship is released under the arrangements,

(b) that person is D or a person who is a related party of D at that time, and

(c) immediately before the release, it is reasonable to conclude that, without the release and any arrangements of which the release forms part, there would be a material risk that, at some time within the next 12 months, D or the related party would be unable to pay its debts.

(4) For the purposes of this section “debtor relationship” has the meaning given by section 302(6) of CTA 2009 (reading the references in that subsection to a company as references to a person).

Ordinary independent financing arrangements by banks and others

470

(1) This section applies where—

(a) at any time, a person (“C”) is party to a loan relationship as creditor and the party to the loan relationship as debtor (“D”) is a related party of C as a result of any circumstances, and

(b) the loan relationship is not one to which C is a party at that time directly or indirectly in consequence of, or otherwise in connection with, the existence of any of those circumstances.

(2) C and D are treated for the purposes of this Part as if, in relation to the loan relationship (and anything done under or for the purposes of it), they were not related parties of each other at that time.

Loans made by relevant public bodies

471

(1) This section applies at any time where—

(a) a relevant public body (“B”) lends money to a person (“P”),

(b) B is a related party of P, and

(2) B and P are treated for the purposes of this Part as if, in relation to the loan (and anything done under or for the purposes of it), they were not related parties of each other at that time.

Finance leases granted before 20 March 2017

472

(1) This section applies at any time where an asset is leased by a person (“A”) to another (“B”) under a lease which is granted before 20 March 2017 and which, in the case of B, is a finance lease.

(2) A and B are treated for the purposes of this Part as if, in relation to the lease (and anything done under or for the purposes of it), they were not related parties of each other at that time.

Determining the worldwide group

Meaning of “a worldwide group”, “ultimate parent” etc

473

(1) In this Part “a worldwide group” means—

(a) any entity which—

(i) is a relevant entity (see section 474), and

(ii) meets the first or second non-consolidation condition (see subsections (2) and (3)), and

(b) each consolidated subsidiary (if any) of the entity mentioned in paragraph (a).

(2) The first non-consolidation condition is that the entity—

(a) is a member of an IAS group, and

(b) is not a consolidated subsidiary of an entity that—

(i) is a relevant entity, and

(ii) itself meets the first non-consolidation condition.

(3) The second non-consolidation condition is that the entity is not a member of an IAS group.

(4) In this Part—

(a) references to “a member” of a worldwide group are to an entity mentioned in subsection (1)(a) or (b);

(b) references to “the ultimate parent” of a worldwide group are to the entity mentioned in subsection (1)(a);

(d) references to “a multi-company worldwide group” are to a worldwide group with two or more members.

(5) In this section “IAS group” means a group within the meaning given by international accounting standards.

Interpretation of section 473: “relevant entity”

474

(1) In section 473 “relevant entity” means—

(a) a company, or

(b) an entity the shares or other interests in which are listed on a recognised stock exchange and are sufficiently widely held.

(2) Shares or other interests in an entity are “sufficiently widely held” if no participator in the entity holds more than 10% by value of all the shares or other interests in the entity.

Section 454 of CTA 2010 (meaning of participator) applies for the purposes of this subsection.

(3) The following are not relevant entities—

(a) the Crown,

(b) a Minister of the Crown,

(d) a Northern Ireland department, or

(e) a foreign sovereign power.

Meaning of “non-consolidated subsidiary” and “consolidated subsidiary”

475

(1) An entity (“X”) is a “non-consolidated subsidiary” of another entity (“Y”) at any time (“the relevant time”) if—

(a) X is a subsidiary of Y at the relevant time, and

(b) if Y were required at the relevant time to measure its investment in X, it would be required to do so using fair value accounting ....

(2) An entity (“X”) is a “consolidated subsidiary” of another entity (“Y”) at any time if, at that time, X is a subsidiary, but not a non-consolidated subsidiary, of Y.

(3) In this section “subsidiary” has the meaning given by international accounting standards.

(4) For the purposes of this section, assume that all entities are subject to international accounting standards.

(5) This section has effect for the purposes of this Part.

Continuity of identity of a worldwide group through time

476

(1) This section applies for the purpose of determining whether a group of entities that constitutes a worldwide group at any time (“Time 2”) is the same worldwide group as a group of entities that constitutes a worldwide group at an earlier time (“Time 1”).

(2) The group at Time 2 is the same worldwide group as the group at Time 1 if and only if the entity that is the ultimate parent of the group at Time 2—

(a) was the ultimate parent of the group at Time 1, and

(b) was the ultimate parent of a worldwide group at all times between Time 1 and Time 2.

Treatment of stapled entities

477

(1) This section applies where two or more entities—

(a) would, apart from this section, each be the ultimate parent of a worldwide group, and

(b) are stapled to each other.

(2) This Part has effect as if—

(a) the entities were consolidated subsidiaries of another entity (the “deemed parent”), and

(b) the deemed parent fell within section 473(1)(a) (conditions for being the ultimate parent of a worldwide group).

(3) For the purpose of this section an entity (“entity A”) is “stapled” to another entity (“entity B”) if, in consequence of the nature of the rights attaching to the shares or other interests in entity A (including any terms or conditions attaching to the right to transfer the interests), it is necessary or advantageous for a person who has, disposes of or acquires shares or other interests in entity A also to have, dispose of or acquire shares or other interests in entity B.

Treatment of business combinations

478

(1) This section applies where two entities—

(a) would, apart from this section, each be the ultimate parent of a worldwide group, and

(b) are treated under international accounting standards as a single economic entity by reason of being a business combination achieved by contract.

(2) This Part has effect as if—

(a) the two entities were consolidated subsidiaries of another entity (the “deemed parent”), and

(b) the deemed parent fell within section 473(1)(a) (conditions for being the ultimate parent of a worldwide group).

(3) In this section “business combination” has the meaning given by international accounting standards.

Financial statements and periods of account

“Financial statements” of a worldwide group

479

(1) References in this Part to “financial statements” of a worldwide group for a period are (subject to subsection (2)) to consolidated financial statements of the worldwide group's ultimate parent and its subsidiaries in respect of the period.

(2) Where the worldwide group is at all times during the period a single-company worldwide group, the references are to financial statements of the ultimate parent in respect of the period.

(3) The basic rule is that the references mentioned in subsections (1) and (2) are to financial statements that are drawn up by or on behalf of the ultimate parent.

(4) But see—

(a) section 481 for provision under which, in specified circumstances, financial statements of a worldwide group are treated as having been drawn up in accordance with different accounting standards from those in accordance with which they are drawn up by or on behalf of the ultimate parent;

(b) section 482 for provision under which, in specified circumstances, financial statements of a worldwide group are treated as consolidating different subsidiaries from those consolidated in financial statements drawn up by or on behalf of the ultimate parent;

(c) section 483 for provision under which, in specified circumstances, financial statements of a worldwide group are treated as having been drawn up where the ultimate parent has drawn up consolidated financial statements covering more than one worldwide group;

(d) sections 484 to 486 for provision under which, where financial statements of a worldwide group are not drawn up by or on behalf of the ultimate parent, financial statements of the group are treated as having been drawn up.

(5) See also section 487 (under which financial statements drawn up by or on behalf of an entity, but for too long a period or too late, are ignored for the purposes of this Part).

“Period of account” of worldwide group

480

References in this Part to a “period of account” of a worldwide group are to—

(a) a period in respect of which financial statements of the group are drawn up by or on behalf of the ultimate parent, or

(b) a period in respect of which financial statements of the group are treated as drawn up for the purposes of this section (whether under any of sections 481 to 485 or under any other enactment).

Actual financial statements not drawn up on acceptable principles

481

(1) This section applies where financial statements of a worldwide group for a period drawn up by or on behalf of the ultimate parent are not drawn up on acceptable principles.

(2) For the purposes of this Part (apart from this section)—

(a) the financial statements mentioned in subsection (1) are to be ignored, and

(b) IAS financial statements of the worldwide group are treated as having been drawn up in respect of the period.

(3) For the purposes of this Chapter financial statements are “drawn up on acceptable principles” only if condition A, B, C or D is met.

(4) Condition A is that the financial statements are IAS financial statements.

(5) Condition B is that the amounts recognised in the financial statements are not materially different from those that would be recognised in IAS financial statements of the worldwide group, if such statements were drawn up.

(6) Condition C is that the financial statements are drawn up in accordance with UK generally accepted accounting practice.

(7) Condition D is that the financial statements are drawn up in accordance with generally accepted accounting principles and practice of one of the following territories—

(a) Canada;

(b) China;

(d) Japan;

(e) South Korea;

(f) the United States of America.

(8) The Commissioners may by regulations amend this section so as to alter the circumstances in which financial statements are “drawn up on acceptable principles” for the purposes of this Chapter.

Actual financial statements drawn up on acceptable principles but consolidating wrong subsidiaries

482

(1) This section applies where financial statements of a worldwide group for a period drawn up by or on behalf of the ultimate parent are drawn up on acceptable principles but—

(a) do not consolidate one or more entities that are IAS subsidiaries, or

(b) consolidate one or more entities that are not IAS subsidiaries.

(2) In this section “IAS subsidiary”, in relation to a period, means an entity which would be required to be consolidated with those of the ultimate parent in IAS financial statements of the group for the period.

(3) For the purposes of this Part (apart from this section)—

(a) the financial statements mentioned in subsection (1) are to be ignored, and

(b) consolidated financial statements of the ultimate parent and its IAS subsidiaries are treated as having been drawn up in respect of the period.

(4) The financial statements treated by subsection (3)(b) as drawn up are treated as drawn up in accordance with the same accounting principles and practice as the financial statements mentioned in subsection (1).

(5) In this section a reference to financial statements consolidating the results of an entity is to consolidating its results with those of the ultimate parent as the results of a single economic entity.

Actual financial statements covering more than one worldwide group

483

(1) This section applies where—

(a) consolidated financial statements of an entity and its subsidiaries are drawn up by or on behalf of the entity in respect of a period (“the actual period of account”), and

(b) the entity was the ultimate parent of a worldwide group for a part (but not all) of that period.

(2) For the purposes of this Part (apart from this section)—

(a) the financial statements mentioned in subsection (1)(a) are to be ignored, and

(b) consolidated financial statements of the entity and its IAS subsidiaries are treated as having been drawn up in respect of the part of the actual period of account mentioned in subsection (1)(b).

(3) The financial statements treated by subsection (2)(b) as drawn up are treated as drawn up—

(a) where the financial statements mentioned in subsection (1)(a) are drawn up on acceptable principles, in accordance with the same accounting principles and practice as those financial statements;

(b) otherwise, in accordance with international accounting standards.

(4) In this section “IAS subsidiary” has the same meaning as in section 482.

No actual financial statements: ultimate parent draws up financial statements

484

(1) Subsection (2) applies where—

(a) financial statements of the ultimate parent of a worldwide group are drawn up by or on behalf of the ultimate parent in respect of a period (“the relevant period”),

(b) consolidated financial statements of the ultimate parent and its subsidiaries are not drawn up by or on behalf of the ultimate parent in respect of the relevant period or any part of it, and

(2) For the purposes of this Part (apart from this section) IAS financial statements of the worldwide group are treated as drawn up in respect of the relevant period.

(3) The ultimate parent may elect that subsection (2) is not to apply in relation to financial statements of the ultimate parent.

(4) An election under subsection (3)—

(a) has effect in relation to financial statements in respect of periods ending on or after such date as is specified in the election, and

(b) is irrevocable.

(5) The date specified in the election may not be before the day on which the election is made.

No actual financial statements: other cases

485

(1) In this section “accounts-free period” means (subject to subsection (2)) any period—

(a) which begins on or after 1 April 2017,

(b) throughout which a worldwide group exists, and

(i) drawn up by or on behalf of the ultimate parent, or

(ii) treated as drawn up for the purposes of this section (whether under section 481, 482, 483 or 484 or any other enactment).

(2) A period is not an “accounts-free period” if it forms part of an accounts-free period.

(3) If an accounts-free period in relation to a worldwide group is 12 months or less, IAS financial statements of the worldwide group are treated for the purposes of this Part (apart from this section) as having been drawn up for the accounts-free period.

(4) If an accounts-free period in relation to a worldwide group is more than 12 months, IAS financial statements of the worldwide group are treated for the purposes of this Part (apart from this section) as having been drawn up for each of the following periods—

(a) the first period of 12 months falling within the accounts-free period;

(b) any subsequent period of 12 months falling within the accounts-free period;

(i) begins immediately after the end of a period mentioned in paragraph (a) or (b), and

(ii) ends at the end of the accounts-free period.

Election altering period of account deemed under section 485

486

(1) This section applies where, disregarding this section, IAS financial statements of a worldwide group would be treated under section 485(4)(a) or (b) as drawn up for a period (“the default period of account”) during an accounts-free period.

(2) The ultimate parent of the group may make an election under this section in relation to the default period of account.

(3) Where an election under this section is made, section 485 has effect as if subsection (4)(a) or (b) of that section—

(a) did not treat IAS financial statements of the group as having been drawn up for the default period of account;

(b) instead, treated IAS financial statements of the group as having been drawn up for the period—

(i) beginning with the day on which the default period of account begins (“the start day”), and

(ii) ending with such day after the start day as is specified in the election (“the end day”).

(4) The end day must—

(a) fall within the accounts-free period, and

(b) not be later than the final day of the period of 18 months beginning with the start day.

(5) An election under this section—

(a) must be made before the end day, and

(b) is irrevocable.

(6) The fact that the ultimate parent of a worldwide group makes an election under this section in relation to a default period of account (“the earlier elected period”) does not prevent it from making an election in relation to a later default period of account (“the later elected period”).

(7) But where it does so, the end day in relation to the later elected period must be 3 years or more after the end day in relation to the earlier elected period.

(8) Where this section modifies section 485(4)(a) or (b) so that it treats IAS financial statements of the group as having been drawn up for the period mentioned in subsection (3)(b) of this section (“the elected period”), section 485(4)(b) and (c) apply in relation to any part of the accounts-free period following the end of the elected period.

(9) In this section “accounts-free period” has the same meaning as in section 485.

Actual financial statements ignored if for too long a period or too late

487

Financial statements drawn up by or on behalf of any entity are to be ignored for the purposes of this Part (apart from this section) if—

(a) the period in respect of which they are drawn up is more than 18 months, or

(b) they are drawn up after the end of the period of 30 months beginning with the beginning of the period in respect of which they are drawn up.

Meaning of “IAS financial statements”

488

(1) References in this Part to “IAS financial statements” of a worldwide group for a period are (subject to subsection (2)) to consolidated financial statements of the worldwide group's ultimate parent and its subsidiaries, drawn up in respect of the period in accordance with international accounting standards.

(2) If the worldwide group is at all times during the period a single-company worldwide group, the references are instead to financial statements of the ultimate parent, drawn up in respect of the period in accordance with international accounting standards.

References to amounts recognised in financial statements

489

(1) References in this Part to an amount “recognised” in financial statements—

(a) include an amount comprised in an amount so recognised;

(b) are, where the amount is expressed in a currency other than sterling, to that amount translated into its sterling equivalent.

(2) The exchange rate by reference to which an amount is to be translated under subsection (1)(b) is the average rate of exchange for the period of account, calculated from daily spot rates.

(3) References in this Part to an amount recognised in financial statements “for a period” as an item of profit or loss include references to an amount that—

(a) was previously recognised as an item of other comprehensive income, and

(b) is transferred to become an item of profit or loss in determining the profit or loss for the period.

Other definitions

Meaning of “relevant accounting period”

490

For the purposes of this Part a “relevant accounting period” of a company, in relation to a period of account of a worldwide group, means any accounting period that falls wholly or partly within the period of account of the worldwide group.

Meaning of “relevant public body”

491

(1) In this Part “relevant public body” means—

(a) the Crown,

(b) a Minister of the Crown,

(d) a Northern Ireland department,

(e) a foreign sovereign power,

(f) a designated educational establishment (within the meaning given by section 106 of CTA 2009),

(g) a health service body (within the meaning given by section 986 of CTA 2010),

(h) a local authority or local authority association,

(i) any other body that acts under any enactment for public purposes and not for its own profit, or

(j) any wholly-owned subsidiary of any body falling within any of the above paragraphs of this subsection.

(2) In this section “enactment” includes—

(a) an enactment contained in subordinate legislation within the meaning of the Interpretation Act 1978,

(b) an enactment contained in, or in an instrument made under, an Act of the Scottish Parliament,

(d) an enactment contained in, or in an instrument made under, Northern Ireland legislation.

(3) The Commissioners may by regulations amend this section so as to alter the meaning of “relevant public body”.

(4) The provision that may be made by the regulations does not include provision altering the meaning of “relevant public body” so that it includes a person who has no functions of a public nature.

Meaning of “UK group company”

492

In this Part “UK group company”, in relation to any time during a period of account of a worldwide group, means a company—

(a) which is within the charge to corporation tax at that time, and

(b) which is a member of the group at that time.

Embedded derivatives

493

Sections 415 and 585 of CTA 2009 (loan relationships with embedded derivatives) apply for the purposes of this Part of this Act.

Other interpretation

494

(1) In this Part—

“the Commissioners” means the Commissioners for Her Majesty's Revenue and Customs;

“fair value accounting” means a basis of accounting under which—assets and liabilities are measured in the company's balance sheet at their fair value, andchanges in the fair value of assets and liabilities are recognised as items of profit or loss;

“fair value” has the meaning it has for accounting purposes;

“finance lease”, in relation to a company or a worldwide group, a lease which—in accordance with generally accepted accounting practice, falls (or would fall) to be treated, in the accounts of the company or the financial statements of the group, as a finance lease or loan, oris a right-of-use lease that would fall to be treated in those accounts or financial statements as a finance lease if the company or group were required to determine for accounting purposes whether the lease falls to be so treated;

“interest restriction return” means a return submitted under any provision of Schedule 7A;

“pension scheme” has the meaning given by section 150(1) of FA 2004;

“reporting company” means a company which is for the time being appointed under any provision of Schedule 7A;

“the return period”, in relation to an interest restriction return of a worldwide group, means the period of account of the group to which the return relates;

“right-of-use lease” means a lease in respect of which, under generally accepted accounting practice—a right-of-use asset falls (or would fall) at the commencement of the lease to be recognised for accounting purposes in the accounts of the lessee, ora right-of-use asset would fall to be so recognised but for the lessee granting a sublease of the leased asset,and, in determining whether a lease falls within paragraph (a) or (b) at any time in an accounting period, it is to be assumed that the accounting policy applied in drawing up the lessee’s accounts for the period also applied at the commencement of the lease;

“service concession arrangement” has the meaning given by international accounting standards;

“wholly-owned subsidiary” has the meaning given by section 1159(2) of the Companies Act 2006.

(2) For the purposes of this Part a person who is not a company is regarded as being a party to a loan relationship if the person would be so regarded for the purposes of Part 5 of CTA 2009 if the person were a company.

(3) The definition of “insurance company” in section 65 of FA 2012 (which is applicable to this Part as a result of section 141(2) of that Act) has effect for the purposes of this Part as if, in subsection (2)(a), the reference to Part 4A of the Financial Services and Markets Act 2000 included a reference to the law of a territory outside the United Kingdom which is similar to or corresponds to that Part.

Regulations

Financial statements: different treatment by group or members

495

(1) The Commissioners may make regulations for the purpose of altering any calculation under Chapter 7 where—

(a) the financial statements of a worldwide group for a period include or omit an amount in respect of any matter, and

(b) any member of the group deals with that matter for tax or accounting purposes in a different way.

(2) The regulations—

(a) may make provision subject to an election or other specified circumstances, and

(b) may make provision having effect in relation to any period beginning before the regulations are made if the period begins at some time in the calendar year in which the regulations are made.

Parties to capital market arrangements

496

(1) The Commissioners may make regulations entitling—

(a) a UK group company which has a liability to corporation tax as a result of this Part and which is a party to a capital market arrangement, and

(b) another UK group company,

to make a joint election transferring the liability to the other UK group company.

(2) The regulations may include provision—

(a) specifying other conditions that must be met for an election to be made,

(b) requiring an election to be made on or before a particular time (for example, before the accounting period for which the liability arises),

(c) authorising or requiring an officer of Revenue and Customs (on the exercise of a discretion or otherwise) to accept or reject an election,

(d) authorising or requiring an officer of Revenue and Customs (on the exercise of a discretion or otherwise) to revoke an election previously in force and dealing with the effect of the revocation, and

(e) dealing with the effect of the transfer of the corporation tax liability on any other liabilities that relate to the transferred corporation tax liability.

(3) In this section “capital market arrangement” has the same meaning as in section 72B(1) of the Insolvency Act 1986 (see paragraph 1 of Schedule 2A to that Act).

Change in accounting standards

497

(1) The Treasury may by regulations amend this Part to take account of a change in the way in which amounts are, or may be, presented or disclosed in financial statements where the change results from the issue, revocation, amendment or recognition of, or withdrawal of recognition from, an accounting standard by an accounting body.

(2) For this purpose—

“accounting standard” includes any statement of practice, guidance or other similar document, and

“accounting body” means—the International Accounting Standards Board (or successor body), orthe Accounting Standards Board (or successor body).

(3) The regulations—

(a) may make provision subject to an election or other specified circumstances, and

(b) may make provision having effect in relation to any period beginning before the regulations are made if the change mentioned in subsection (1) is relevant to that period.

(4) A statutory instrument containing regulations which are capable of increasing the liability of a company to corporation tax may not be made unless a draft of the instrument is laid before, and approved by a resolution of, the House of Commons.

Regulations

498

Regulations under this Part may—

(a) make different provision for different cases or circumstances,

(b) include supplementary, incidental and consequential provision, or

Part 11 — General provisions

Subordinate legislation

Orders and regulations

499

(1) Any power of the Treasury or the Commissioners for Her Majesty's Revenue and Customs to make any order or regulations under this Act is exercisable by statutory instrument.

(2) Any statutory instrument containing any order or regulations made by the Treasury or the Commissioners for Her Majesty's Revenue and Customs under this Act is subject to annulment in pursuance of a resolution of the House of Commons.

(3) Subsection (2) does not apply—

(a) in relation to regulations under section 7 (double taxation relief: general regulations),

(b) in relation to regulations under section 354(1) or 359(2) (offshore funds) if a draft of the statutory instrument containing the regulations has been laid before and approved by a resolution of the House of Commons,

(c) in relation to an order under section 377(2) (transitional or saving provision in connection with coming into force of this Act), or

(d) if any other Parliamentary procedure is expressly provided to apply in relation to the order or regulations.

(4) Section 828 of ICTA (which includes provision about orders made before 1 April 2010 under provisions of the Corporation Tax Acts not contained in ICTA) does not apply in relation to an order made by the Treasury under this Act before 1 April 2010.

Interpretation

Abbreviated references to Acts

500

In this Act—

“CAA 2001” means the Capital Allowances Act 2001,

“CTA 2009” means the Corporation Tax Act 2009,

“CTA 2010” means the Corporation Tax Act 2010,

“FA”, followed by a year, means the Finance Act of that year,

“F(No.2)A”, followed by a year, means the Finance (No. 2) Act of that year,

“ICTA” means the Income and Corporation Taxes Act 1988,

“ITA 2007” means the Income Tax Act 2007,

“ITEPA 2003” means the Income Tax (Earnings and Pensions) Act 2003,

“ITTOIA 2005” means the Income Tax (Trading and Other Income) Act 2005,

“TCGA 1992” means the Taxation of Chargeable Gains Act 1992, and

“TMA 1970” means the Taxes Management Act 1970.

Final provisions

Minor and consequential amendments

501

Schedule 8 (minor and consequential amendments, including amendments for purposes connected with other tax law rewrite Acts) has effect.

Transitional provisions and savings

502

(1) Schedule 9 (transitional provisions and savings) has effect.

(2) The Treasury may by order make such transitional or saving provision as the Treasury consider appropriate in connection with the coming into force of this Act.

(3) An order under this section may contain provision having retrospective effect.

Repeals and revocations

503

(1) Schedule 10 (repeals and revocations, including of spent enactments and including repeals for purposes connected with other tax law rewrite Acts) has effect.

(2) If—

(a) CTA 2010 repeals or revokes a provision and the repeal or revocation is for corporation tax purposes only (see section 1181(2) of that Act), and

(b) this Act also repeals or revokes the provision,

the repeal or revocation of the provision by this Act is for all purposes other than corporation tax purposes.

Index of defined expressions

504

(1) Schedule 11 (index of defined expressions that apply for purposes of Parts 2 to 10) has effect.

(2) That Schedule lists the places where some of the expressions used in Parts 2 to 10 are defined or otherwise explained.

Extent

505

(1) This Act extends to England and Wales, Scotland and Northern Ireland (but see subsection (2)).

(2) An amendment, repeal or revocation contained in Schedule 7, 8 or 10 has the same extent as the provision amended, repealed or revoked.

Commencement

506

(1) This Act comes into force on 1 April 2010 and has effect—

(a) for corporation tax purposes, for accounting periods ending on or after that day,

(b) for income tax and capital gains tax purposes, for the tax year 2010-11 and subsequent tax years, and

(2) Subsection (1) does not apply to the following provisions (which therefore come into force on the day on which this Act is passed)—

(a) section 499,

(b) section 500,

(d) section 501 so far as relating to those amendments,

(e) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

(f) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

(g) section 502(2) and (3),

(h) section 505,

(i) this section, and

(j) section 507.

Short title

507

This Act may be cited as the Taxation (International and Other Provisions) Act 2010.

Schedule A1 — Assessment of unassessed transfer pricing profits: partnerships and Lloyd’s syndicates

Part 1 — Corporate partner’s unassessed transfer pricing profits

Unassessed transfer pricing profits: corporate partners

1

(1) For the purposes of this Part of this Act, a company has unassessed transfer pricing profits as a corporate partner of a partnership in relation to a return period if—

(a) the company is or has been a partner in the partnership;

(b) a partnership return in respect of the partnership has been made and delivered in respect of the return period,

(c) provision has been made or imposed as between the partnership and another person by means of a transaction or series of transactions,

(d) the partnership’s profits and losses calculated under section 1259 of CTA 2009 for one or more relevant accounting periods are subject to a transfer pricing requirement in relation to that provision,

(e) a share of the partnership’s profit or loss calculated under section 1259 of CTA 2009 for one or more of those relevant accounting periods is brought into account in calculating the company’s profit or loss for one or more accounting periods for corporation tax purposes, and

(f) the transfer pricing requirement was not reflected, or is not wholly reflected, in the partnership’s profits and losses that were—

(i) included in the partnership return, and

(ii) calculated under section 1259 of CTA 2009.

(2) For the purposes of this Part of this Act, the unassessed transfer pricing profits of the company for an accounting period are the profits that would be brought into account in calculating the company’s profit or loss for that accounting period for corporation tax purposes, if the amount of the partnership’s profit calculated under section 1259 of CTA 2009 for each of the relevant accounting periods mentioned in sub-paragraph (1)(e) was taken to be the amount of the partnership’s unassessed transfer pricing profits for that relevant accounting period (and no other amount).

(3) For the purposes of sub-paragraph (2), the partnership’s unassessed transfer pricing profits for a relevant accounting period are—

(a) to the extent that the transfer pricing requirement requires profits that are not reflected in the partnership return to be brought into account in calculating the partnership’s profits or losses calculated under section 1259 of CTA 2009 for the relevant accounting period, those profits, and

(b) to the extent that the transfer pricing requirement requires losses that are reflected in the partnership’s return to not be brought into account in calculating the partnership’s profits or losses calculated under section 1259 of CTA 2009 for the relevant accounting period, the profits that would, if they were brought into account in that calculation, produce the same result as not bringing into account those losses.

(4) The partnership’s profits and losses calculated under section 1259 of CTA 2009 for a relevant accounting period are subject to a transfer pricing requirement in relation to the provision if—

(a) the partnership’s profits and losses calculated under section 1259 of CTA 2009 for the relevant accounting period are required to be calculated as if the arm’s length provision (within the meaning of Part 4) had been made or imposed instead of the provision, or

(b) an adjustment to the partnership’s profits and losses calculated under section 1259 of CTA 2009 for the relevant accounting period that result from the provision is required by virtue of any other enactment where, but for that enactment, paragraph (a) would have applied in relation to the provision.

(5) In this paragraph—

(a) for the purposes of sub-paragraph (1)(a), a company that is or has been a partner in the partnership includes a company that is or has been an indirect partner in the partnership for the purposes of section 12AA of TMA 1970, and

(b) accordingly, the reference in sub-paragraph (2) to the partnership’s profits or losses being brought into account in calculating the profit or loss of a company that is or has been a partner in a partnership includes those profits or losses being brought into account indirectly.

(6) In Parts 1 to 3 of this Schedule—

(a) “partnership return” means a return in pursuance of a notice under section 12AA(2) or (3) of TMA 1970 (and where the return has been amended, reference to the return is to that return as amended);

(b) “relevant corporate partner”, in relation to a partnership and a return period, means a company which has unassessed transfer pricing profits for one or more accounting periods as a corporate partner of the partnership in relation to the return period by virtue of this paragraph (and references to the relevant corporate partner’s unassessed transfer pricing profits are to be construed accordingly);

(c) “return period” means the period in respect of which a partnership return is required pursuant to the notice under section 12AA(2) or (3) of TMA 1970;

(d) “relevant accounting period”, in relation to a partnership return, means an accounting period of the firm (within the meaning of Part 17 of CTA 2009) ending within the return period.

Part 2 — Conditions for being assessed

Conditions for being assessed

2

(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—

(a) references to the other party were to the other person mentioned in paragraph 1(1)(c);

(b) the reference in section 217D(1) to the company were a reference to the partnership;

(c) where the partnership has more than one relevant corporate partner in relation to the return period, for section 217D(2) there were substituted—

(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.

(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.

(2) In sub-paragraph (1)(d) “the relevant corporate partners’ proportion” means the proportion that—

(a) where the partnership has one relevant corporate partner, the relevant corporate partner’s unassessed transfer pricing profits, or

(b) where the partnership has more than one relevant corporate partner, the sum of each relevant corporate partner’s unassessed transfer pricing profits,

bears to the partnership’s unassessed transfer pricing profits within the meaning of paragraph 1(3) of this Schedule.

Part 3 — Assessment

Preliminary notices

3

(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).

Representations by the partnership

4

Section 217G has effect in relation to a preliminary notice issued to the representative partner under paragraph 3 as it has effect in relation to a preliminary notice issued to a company but as if the reference in subsection (4) of that section to the other party were to the other person mentioned in paragraph 1(1)(c).

Assessment

5

(1) This paragraph applies where—

(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

(b) a designated officer has considered any representations made by the representative partner in accordance with section 217G (as applied by paragraph 4).

(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.

(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—

(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;

(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.

(4) Notices of any assessments under this paragraph issued to a relevant corporate partner must also be issued to the representative partner.

(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—

(a) the reference in subsection (4) to the other party were to the other person mentioned in paragraph 1(1)(c),

(b) references to paragraph 33 of Schedule 18 to FA 1998 were to section 28B of TMA 1970, and

(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).

Amendment of partnership return by partnership

6

(1) This paragraph applies where a designated officer assesses the unassessed transfer pricing profits of all of the relevant corporate partners of a partnership in relation to a return period under paragraph 5.

(2) At any time before the end of the period for amendments, the representative partner may amend the partnership return for the return period so that the calculation of the partnership’s profits and losses under section 1259 of CTA 2009 more fully reflects the transfer pricing requirement to which the unassessed transfer pricing profits relate.

(3) In this Part of this Schedule “the period for amendments” means the period of 15 months beginning with the day after the day on which the designated officer assesses the unassessed transfer pricing profits of all of the relevant corporate partners under paragraph 5.

(4) If, before the end of the period of 15 months referred to in sub-paragraph (3), a designated officer and the representative partner agree (in writing) that the period for amendments is to terminate, the period ends when that agreement is made.

(5) An amendment under sub-paragraph (2) may not be made in the last 21 days of the period for amendments, unless the period for amendments ends by agreement in accordance with sub-paragraph (4).

(6) Section 12AD(3) of TMA 1970 (amendment not to take effect during enquiry) does not apply in relation to an amendment made under sub-paragraph (2).

Amendment of assessment by HMRC

7

(1) This paragraph applies where a designated officer assesses the unassessed transfer pricing profits of all of the relevant corporate partners of a partnership in relation to a return period under paragraph 5.

(2) If at any time before the end of the period for amendments a designated officer is satisfied that the total corporation tax charged on any relevant corporate partner’s unassessed transfer pricing profits for an accounting period by an assessment under paragraph 5 is excessive, the designated officer must amend or withdraw the assessment accordingly.

(3) If at any time (whether or not before the end of the period for amendments) a designated officer is satisfied that one or more of the conditions mentioned in section 217C(1) do not apply in respect of unassessed transfer pricing profits so assessed, the designated officer must—

(a) withdraw all of the assessments made under paragraph 5, or

(b) amend all of the assessments to assess the unassessed transfer pricing profits to corporation tax not at the UTPP rate.

(4) Where an assessment is amended under sub-paragraph (2) or (3) any tax overpaid must be repaid.

(5) If a designated officer is satisfied at any time before the end of the period for amendments that the total corporation tax charged on any relevant corporate partner’s unassessed transfer pricing profits for the period is insufficient, the designated officer may amend the assessment accordingly.

(6) An amendment under sub-paragraph (5) may not be made in the last 30 days of the period for amendments, unless the period for amendments ends by agreement in accordance with paragraph 6(4).

(7) Where an assessment is withdrawn or amended under this paragraph, notice of the withdrawal or amendment must be given to the representative partner.

No postponement except before assessment is finalised for tax on same profits

8

(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;

(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.

Closure notices: rules relating to period for amendments

9

(1) This paragraph applies where a designated officer assesses the unassessed transfer pricing profits of all of the relevant corporate partners of a partnership in relation to a return period under paragraph 5.

(2) A relevant closure notice may not be issued under section 28B of TMA 1970 at any time before the end of the period for amendments.

(3) Accordingly, a tribunal direction given under section 28B of TMA 1970 in relation to a relevant closure notice has no effect until the period for amendments has ended.

(4) A relevant closure notice issued after the end of the period for amendments may not make any amendments to the partnership return which have the effect that the calculation of the partnership’s profits and losses under section 1259 of CTA 2009 more fully reflects the transfer pricing requirement to which the unassessed transfer pricing profits relate.

(5) In this paragraph a “relevant closure notice” means a partial or final closure notice in relation to an enquiry into the partnership return for the return period mentioned in sub-paragraph (1).

Appeal against assessment

10

(1) An appeal against the assessment of the unassessed transfer pricing profits of a relevant corporate partner of a partnership in relation to a return period under this Schedule may only be made—

(a) by the representative partner, and

(b) where the partnership has more than one relevant corporate partner in relation to the return period, by the representative partner appealing at the same time against the assessments of the unassessed transfer pricing profits of all of the relevant corporate partners.

(2) The representative partner in the partnership may only bring an appeal against such an assessment where—

(a) all of the relevant corporate partners have paid (in full) the corporation tax charged on the profits assessed other than any amount the payment of which has been postponed in accordance with paragraph 8, and

(b) the period for amendments has ended.

(3) Notice of an appeal must be given before the end of the period of 30 days beginning with—

(a) the end of the period for amendments, or

(b) in a case where paragraph 6(4) applies, the day after the day on which the period for amendments ends,

(and accordingly paragraph 48(2)(b) of Schedule 18 to FA 1998 does not apply).

(4) Sub-paragraphs (5) and (6) apply where, on an appeal against an assessment of a relevant corporate partner’s unassessed transfer pricing profits, the tribunal decides that the company is overcharged by the assessment as a result of one or more of the conditions mentioned in section 217C(1) not applying in respect of unassessed transfer pricing profits so assessed.

(5) The tribunal may, in addition to any other powers exercisable by the tribunal in those circumstances, reduce the tax charged on the amount assessed to assess the unassessed transfer pricing profits to corporation tax not at the UTPP rate.

(6) But where the partnership has more than one relevant corporate partner in relation to the return period the tribunal may only exercise the power in sub-paragraph (5) if the tribunal exercises the power on the appeal against the assessment of the unassessed transfer pricing profits of each relevant corporate partner.

Review of assessment

11

In its application in relation to an appeal against the assessment of the unassessed transfer pricing profits of a relevant corporate partner of a partnership in relation to a return period in respect of which the partnership has more than one relevant corporate partner, section 217N has effect as if after subsection (2) there were inserted—

(3) But the review may only conclude that the assessment is to be amended as described in subsection (2) if the review concludes that the assessment of each of the relevant corporate partner’s unassessed transfer pricing profits is to be amended in that way.

Settling of appeal by agreement

12

(1) Where the representative partner gives notice of appeal against an assessment of the unassessed transfer pricing profits of a relevant corporate partner of a partnership in relation to a return period, references in section 54 of TMA 1970 to an agreement that the assessment should be varied are to be read as including a reference to an agreement that the assessment should be amended to assess the unassessed transfer pricing profits to corporation tax not at the UTPP rate.

(2) But where the partnership has more than one relevant corporate partner in relation to the return period, an agreement that the assessment should be amended as described in sub-paragraph (1) may only be made if an agreement of that kind is made in relation to the assessment of each of the relevant corporate partner’s unassessed transfer pricing profits.

Part 4 — Application to Lloyd’s syndicates

Introduction

13

(1) Parts 1 to 3 of this Schedule apply to a company as a corporate member of a syndicate as they apply to a company as a corporate partner of a partnership as if references to—

(a) partnership were to syndicate;

(b) corporate partner or corporate partners were to corporate member or corporate members;

(d) return period were to underwriting year;

(e) the representative partner were to the syndicate’s managing agent;

(f) “calculated under section 1259 of CTA 2009” were omitted.

(2) The application of Parts 1 to 3 of this Schedule to a corporate member of a syndicate is also subject to the modifications set out in paragraph 14.

(3) For the purposes of this Part of this Schedule—

(a) “corporate member”, in relation to a syndicate—

(i) means a body corporate which is a member of Lloyd’s and is or has been an underwriting member, and

(ii) where the body corporate is a partnership, includes any company that is or has been a partner in that partnership (and for these purposes, partner includes any person who is or has been an indirect partner in the partnership within the meaning of section 12AA of TMA 1970);

(b) “syndicate” and “underwriting year” have the same meanings as in Chapter 5 of Part 4 of FA 1994 (see section 230 of that Act);

(c) “managing agent” and “syndicate return” have the same meanings as in regulation 4 of the Lloyd’s Underwriters (Tax) Regulations 2005 (S.I. 2005/3338).

Modifications to Parts 1 to 3 of this Schedule

14

(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;

(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.

SCHEDULE 1 — Oil activities: new Chapter 16A of Part 2 of ITTOIA 2005

1

ITTOIA 2005 is amended as follows.

2

After section 225 insert—

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