Taxation (International and Other Provisions) Act 2010 section 194

Claims under section 192(1): general provisions

Section 194 sets out who may make a claim under section 192 (which allows certain amounts to be attributed to a guarantor company) and applies general claim procedures to such claims.

• A claim under section 192(1) may be made by the guarantor company, by two or more guarantor companies acting together, or by the issuing company
• Where the issuing company makes the claim, it is treated as having been made on behalf of the guarantor company or companies
• The general claim rules from sections 175 to 177 apply to these claims, but with references adapted so that the issuing company stands in place of the advantaged person
• Similarly, references to the disadvantaged person in the time limit rules are read as references to the guarantor company or companies

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