Section 217S | Assessment otherwise than at UTPP rate: no deduction for excess losses

(1)Where an assessment under this Part is amended to assess the unassessed transfer pricing profits to corporation tax otherwise than at the UTPP rate, no deduction from the unassessed transfer pricing profits is allowed for excess losses.

(2)“Excess losses” means any losses—

(a)that are reflected in the company’s self assessment, and

(b)that the transfer pricing requirement to which the unassessed transfer pricing profits relate requires to not be brought into account in calculating the company’s profits or loss for the period for corporation tax purposes.