Taxation (International and Other Provisions) Act 2010 Schedule 9 paragraph 31

Periods of account in relation to which Part 7 does not have effect

Paragraph 31 of Schedule 9 identifies the periods of account for which the thin capitalisation and transfer pricing rules in Part 7 do not apply, based on when the relevant provisions first came into force.

• The transfer pricing rules in Part 7 do not apply to periods of account that ended before the original legislation took effect, meaning periods of account ending before 1 April 1999 for corporation tax purposes or before 6 April 1999 for income tax purposes.
• This preserves the original commencement dates from the earlier transfer pricing legislation (originally in Schedule 28AA of the Income and Corporation Taxes Act 1988), ensuring the rules are not applied retrospectively to earlier periods.
• The Finance (No. 2) Act 2017 amended this provision as part of wider updates to the transfer pricing framework, but the fundamental principle of non-retrospective application remains unchanged.
• In practice, this paragraph is now largely historical in nature, as it protects periods of account that ended over two decades ago, but it remains part of the statutory framework to preserve legal certainty.

---