The International Controlled Transaction Reporting Regulations 2026
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Change 1
2 Interpretation
(1) In these Regulations— “FA 2026” means the Finance Act 2026; “managing agent” has the same meaning as in regulation 2 of the Lloyd’s Underwriters (Tax) Regulations 2005; “member” has the same meaning as in section 230 of the Finance Act 1994; “relevant partner” means a person who was a partner in the partnership to which the relevant return relates at any time during the period in respect of which the relevant return was required, including the representative partner; “relevant return” means the— company tax return required to be delivered under paragraph 3 of Schedule 18 to the Finance Act 1998, partnership return required to be delivered under section 12AA of the TMA 1970, or syndicate return required to be delivered by regulation 4(1) of The Lloyd’s Underwriters (Tax) Regulations 2005, which corresponds to the accounting period, or underwriting year, to which the specified international controlled transaction relates; “reporting entity” is the person specified as a reporting entity in regulation 16 or 17; “representative partner” means the partner who is required to make and deliver the relevant return to which the specified international controlled transaction relates, or that partner’s successor, in accordance with section 12AA of the TMA 1970; “specified information” is information of a description specified in regulation 18; “specified international controlled transaction” is an international controlled transaction specified in regulation 14; “syndicate” has the same meaning as in section 184(1) of the Finance Act 1993; “the tribunal” means the First-tier Tribunal, or, where determined by or under Tribunal Procedural Rules, the Upper Tribunal; “underwriting year” has the same meaning as in section 184(1) of the Finance Act 1993. (2) In these Regulations “partnership” includes a limited liability partnership. (3) Other expressions used in these Regulations have the same meaning as in the— (a) CTA 2009; (b) CTA 2010; (c) TMA 1970; (d) TIOPA 2010.
2 Interpretation
(1) In these Regulations— “FA 2026” means the Finance Act 2026; “managing agent” has the same meaning as in regulation 2 of the Lloyd’s Underwriters (Tax) Regulations 2005; “member” has the same meaning as in section 230 of the Finance Act 1994; “relevant partner” means a person who was a partner in the partnership to which the relevant return relates at any time during the period in respect of which the relevant return was required, including the representative partner; “relevant return” means the— company tax return required to be delivered under paragraph 3 of Schedule 18 to the Finance Act 1998, partnership return required to be delivered under section 12AA of the TMA 1970, or syndicate return required to be delivered by regulation 4(1) of The Lloyd’s Underwriters (Tax) Regulations 2005, which corresponds to the accounting period, or underwriting year, to which the specified international controlled transaction relates; “reporting entity” is the person specified as a reporting entity in regulation 16 or 17; “representative partner” means the partner who is required to make and deliver the relevant return to which the specified international controlled transaction relates, or that partner’s successor, in accordance with section 12AA of the TMA 1970; “specified information” is information of a description specified in regulation 18; “specified international controlled transaction” is an international controlled transaction specified in regulation 14; “syndicate” has the same meaning as in section 184(1) of the Finance Act 1993; “the tribunal” means the First-tier Tribunal, or, where determined by or under Tribunal Procedural Rules, the Upper Tribunal; “underwriting year” has the same meaning as in section 184(1) of the Finance Act 1993. (2) In these Regulations “partnership” includes a limited liability partnership. (3) Other expressions used in these Regulations have the same meaning as in the— (a) CTA 2009; (b) CTA 2010; (c) TMA 1970; (d) TIOPA 2010.
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