Finance Act 2015

Commencement

8 (1) The amendments made by paragraph 6 of this Schedule (and the amendments made by paragraphs 1 to 5, so far as relating to those amendments) have effect for accounting periods of CFCs beginning on or after 1 April 2015.

(2) Sub-paragraph (3) applies where a CFC has an accounting period beginning before 1 April 2015 and ending on or after that date (“the straddling period”).

(3) For the purposes of the amendments made by paragraph 6—

(a) so much of the straddling period as falls before 1 April 2015, and so much of that period as falls on or after that date, are treated as separate accounting periods, and

(b) any amount charged on a company in accordance with section 371BC of TIOPA 2010 in relation to the straddling period is apportioned to the two separate accounting periods—

(i) on a time basis according to the respective lengths of the separate accounting periods, or

(ii) if that method would produce a result that is unjust or unreasonable, on a just and reasonable basis.

(4) In determining whether an amount falls within section 371UD(9)(a) or (b) of TIOPA 2010 (inserted by this Schedule), paragraph 7(3) and (4) applies as it applies for the purposes of Chapter 3 of Part 7A of CTA 2010.

(5) In this paragraph “CFC” has the same meaning as in Part 9A of TIOPA 2010.