PART 4Income tax, corporation tax and capital gains tax
Corporation tax
36CFC charge: abolition of relief
1
In Part 9A of TIOPA 2010 (controlled foreign companies), omit section 371UD (relief against sum charged).
2
Accordingly, omit the following provisions—
a
in CTA 2010, section 398D(6) and (6A);
b
in FA 2012, in Schedule 20, paragraph 38;
c
in FA 2015, in Schedule 2, paragraphs 6 and 8;
d
in the Corporation Tax (Northern Ireland) Act 2015, in Schedule 2, paragraph 3.
3
The amendments made by this section have effect in relation to accounting periods of CFCs beginning on or after 8 July 2015.
4
Subsection (5) applies where a CFC has an accounting period beginning before 8 July 2015 and ending on or after that date (“the straddling period”).
5
For the purposes of determining the relief to which a chargeable company in relation to the straddling period is entitled under section 371UD of TIOPA 2010, or on the making of a claim would be so entitled—
a
so much of the straddling period as falls before 8 July 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 the company in accordance with section 371BC of TIOPA 2010 in relation to the straddling period is to be apportioned on a just and reasonable basis between those two periods.
6
In this section, “CFC”, “accounting period” in relation to a CFC, and “chargeable company” have the same meanings as in Part 9A of TIOPA 2010.