Taxation (International and Other Provisions) Act 2010 section 182

Making of section 182 claims

Section 182 sets out who may make a transfer pricing claim under this section, the time limits for doing so, and the basic procedural requirements.

• Either the disadvantaged person or the advantaged person may make the claim, but if the advantaged person makes it, the claim is treated as made on behalf of the disadvantaged person.
• The claim may be made before or after the advantaged person has calculated their profits on the arm's length basis, allowing early certainty on the tax consequences.
• The claim must be made within the same time limits that apply to claims under section 174 (as set out in section 177).
• The time limit for making a claim may be extended in certain circumstances under section 186.