The International Controlled Transaction Reporting Regulations 2026
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Change 1
16 Specification of a reporting entity where a transaction meets the transfer pricing condition
(1) Where, within an accounting period or underwriting year a transaction meets the transfer pricing condition, the reporting entity is the— (a) UK resident company in a case falling within section 48(4)(c)(i) of the FA 2026 except where regulation 16(1)(c) applies; (b) non-UK resident company in a case falling within section 48(4)(c)(ii) of the FA 2026; (c) managing agent of the syndicate where a person falls within section 48(4)(c)(i) or (iii) of the FA 2026 and— (i) the person is a member, or managing agent, of a syndicate, and (ii) the transaction is relevant to the determination of syndicate profits included in the syndicate return for the underwriting year; (d) representative partner where a person is a partnership falling within section 48(4)(c)(iii) of the FA 2026. (2) Where paragraph (1)(b) applies, a non-UK resident company is a reporting entity only in respect of those transactions that are relevant to the determination of the charge to corporation tax under section 5(2)(a), (c), or (d), of the CTA 2009.
16 Specification of a reporting entity where a transaction meets the transfer pricing condition
(1) Where, within an accounting period or underwriting year a transaction meets the transfer pricing condition, the reporting entity is the— (a) UK resident company in a case falling within section 48(4)(c)(i) of the FA 2026 except where regulation 16(1)(c) applies; (b) non-UK resident company in a case falling within section 48(4)(c)(ii) of the FA 2026; (c) managing agent of the syndicate where a person falls within section 48(4)(c)(i) or (iii) of the FA 2026 and— (i) the person is a member, or managing agent, of a syndicate, and (ii) the transaction is relevant to the determination of syndicate profits included in the syndicate return for the underwriting year; (d) representative partner where a person is a partnership falling within section 48(4)(c)(iii) of the FA 2026. (2) Where paragraph (1)(b) applies, a non-UK resident company is a reporting entity only in respect of those transactions that are relevant to the determination of the charge to corporation tax under section 5(2)(a), (c), or (d), of the CTA 2009.
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