Effect of a TTH election: corporation tax
18(1)Paragraphs 16 and 17 are subject to this paragraph.
(2)If, on or after the licence transfer date, the seller’s eligible ring fence profits for a pre-transfer accounting period are reduced to an amount which is lower than the transferred profits amount for that period—
(a)the seller is treated as incurring a loss in a ring fence trade, of an amount equal to the difference, for the accounting period, and
(b)paragraph 17 does not apply to the difference.