Taxation (International and Other Provisions) Act 2010 section 177

Time for making, or amending, claim under section 174

Section 177 sets out the time limits within which a disadvantaged person must make or amend a transfer pricing compensation claim under section 174.

• A claim must be made within two years of the advantaged person filing a return that reflects the transfer pricing adjustment, or within two years of the advantaged person receiving a relevant notice containing such a determination.
• If a claim has already been made based on the advantaged person's return, and a relevant notice is subsequently issued to the advantaged person, the disadvantaged person may amend the existing claim within two years of that notice being given.
• The two-year deadline runs from the date the return was made or the date the relevant notice was given, depending on which triggered the right to claim.
• These time limits may be extended under section 186(3), which provides for an extension of the period for making or amending a claim in certain circumstances.

---