Taxation (International and Other Provisions) Act 2010 section 190

Meaning of "relevant notice"

Section 190 defines what counts as a "relevant notice" for the purposes of the transfer pricing chapter, covering the various types of HMRC notices that can trigger or relate to transfer pricing adjustments.

• A "relevant notice" includes closure notices issued by HMRC at the end of an enquiry into personal, trustee, partnership, or company tax returns.
• It also includes notices amending a partnership return where HMRC has discovered a loss of tax.
• Discovery assessments and discovery determinations issued under the corporation tax self-assessment rules are also treated as relevant notices.
• For income tax purposes, a notice of assessment raised by HMRC where a loss of tax has been discovered likewise qualifies as a relevant notice.