Taxation (International and Other Provisions) Act 2010 section 181

Section 182 applies to claims where actual provision relates to a security

Section 181 establishes when a special claims procedure (under section 182) is available for transfer pricing adjustments involving securities issued between two connected companies.

• This section applies only where both affected persons are companies and the actual provision between them relates to a security issued by one of those companies.
• Where these conditions are met, a claim for corresponding tax relief under section 174 may be made using the special procedure set out in section 182 — referred to throughout as a "section 182 claim".
• The definition of "security" is broad and includes securities that do not create or evidence a charge on assets.
• Interest payable on money advanced without a formal security being issued, or other consideration given for the use of such money, is treated as though it were payable in respect of a security issued by the borrowing company — effectively bringing informal lending arrangements within scope.