Taxation (International and Other Provisions) Act 2010 Explanatory Notes

Section 176: Claims under section 174: advantaged person must have made return

363.As a result of this section a claim under section 174 may not be made by the disadvantaged person unless an arm’s length calculation of the advantaged person’s profits has been made and the claim is in accordance with that calculation. It is based on paragraph 6(3) and (4) of Schedule 28AA to ICTA.

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