Finance Act 2022

52 Anti-forestalling: accelerated profits

(1) This section applies if—

(a) trading profits derived from RPD activities arise to an RP developer in an accounting period ending before 1 April 2022,

(b) the profits arise in that accounting period instead of an accounting period ending on or after that date as a result of arrangements entered into on or after 29 April 2021, and

(c) the main purpose, or one of the main purposes, of the arrangements is to secure that, but for this section, the profits would not be taken into account for the purposes of section 38.

(2) The profits are to be taken into account for the purposes of that section as if they arose to the RP developer in the RP developer’s first accounting period ending on or after 1 April 2022.

(3) In this section “arrangements” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable), but does not include a change in the RP developer’s accounting date for the purposes of section 10 of CTA 2009 (end of accounting period).