Taxation (International and Other Provisions) Act 2010 section 184

Amending a section 182 claim if it is followed by relevant notice

Section 184 allows either the advantaged or disadvantaged person to amend a previously made compensating adjustment claim (a section 182 claim) when HMRC subsequently issues a closure notice or similar determination to the advantaged person, and sets out the time limits for doing so.

• Where a compensating adjustment claim has already been made under section 182, and HMRC subsequently issues a formal notice (such as a closure notice) to the advantaged person containing a transfer pricing determination, the claim may need to be amended to reflect that determination.
• Either the disadvantaged person or the advantaged person may make the necessary amendment to the original claim.
• If the advantaged person makes the amendment, it is treated as having been made on behalf of the disadvantaged person.
• Any such amendment must be made within the time limit set out in section 177(3), although this deadline may be extended in certain circumstances under section 186(3).