Finance Act 2021

40 (1) Part 6 of this Schedule (allocation of dual inclusion income within group) has effect in relation to accounting periods of a claimant company that begin on or after 1 January 2021.

(2) A “claimant company” is a company that makes an allocation claim for the purposes of Chapter 12A of Part 6A of TIOPA 2010 (inserted by Part 6 of this Schedule).

(3) For the purposes of sub-paragraph (1), where there is a straddling period—

(a) so much of the straddling period as falls before 1 January 2021, and so much of it as falls on or after that date, are to be treated as separate accounting periods, and

(b) if it is necessary to apportion an amount for the straddling period to the two separate periods, it is to be apportioned—

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

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

(4) A “straddling period” is an accounting period beginning before 1 January 2021 and ending on or after that date.