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Taxation (International and Other Provisions) Act 2010

Section 91: Counteraction notices given before tax return made

205.This section meshes the DTR legislation in with the machinery of Self Assessment in cases in which a counteraction notice is given before the taxpayer’s tax return is made for the chargeable period specified in the notice. It is based on section 804ZC(1), (2) and (11) of ICTA.

206.Subsection (1) includes a minor change in the law. See Change 2 in Annex 1 and the commentary on section 81.

207.Section 804ZC(2)(b) and (11)(b) of ICTA refer to the taxpayer amending the return “for the purpose of complying with the notice”. To sharpen the drafting, subsections (2)(b) and (3)(a) refer to the taxpayer amending the return “for the purpose of complying with the provision referred to in the notice”.

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