Corporation Tax Act 2010

11 (1) This paragraph applies if— U.K.

(a) a loss of a company (arising in an accounting period ending on or after 1 April 2010) (“the loss”) is required by section 7, 8 or 9 to be translated from a currency other than sterling into its sterling equivalent, and

(b) the loss is to be a carried-back amount that is to be carried back to an accounting period beginning before 29 December 2007.

(2) Section 12 (sterling equivalents: carried-back amounts) does not have effect in relation to the loss.

(3) The translation must be made by reference to—

(a) the average exchange rate for the accounting period mentioned in sub-paragraph (1)(a), or

(b) the rate mentioned in sub-paragraph (4).

(4) That rate is—

(a) if the amount to be translated relates to a single transaction, an appropriate spot rate of exchange for the transaction, or

(b) if the amount to be translated relates to more than one transaction, a rate of exchange derived on a just and reasonable basis from appropriate spot rates of exchange for those transactions.

(5) In this paragraph “carried-back amount” has the same meaning as in Chapter 4 of Part 2 (see section 17(2)).