Income Tax Act 2007

Part 2 Changes in the law

10 (1) This paragraph applies if, in the case of any person—

(a) a thing is done or an event occurs before 6 April 2007, and

(b) because of a change in the law made by this Act, the tax consequences of that thing or event for the relevant period are different from what they would otherwise have been.

(2) If that person so elects, this Act applies with such modifications as may be necessary to secure that the tax consequences for the relevant period are the same as they would have been if the change in the law had not been made.

(3) In sub-paragraphs (1) and (2) “the relevant period” means—

(a) for income tax purposes, any period of account beginning before and ending on or after 6 April 2007, and

(b) for corporation tax purposes, any accounting period beginning before and ending on or after 6 April 2007.

(4) If this paragraph applies in the case of two or more persons in relation to the same thing or event, an election made under this paragraph by any one of those persons is of no effect unless a corresponding election is made by the other or each of the others.

(5) An election under this paragraph must be made—

(a) for income tax purposes, on or before the first anniversary of the normal self-assessment filing date for the tax year in which the period of account ends, and

(b) for corporation tax purposes, not later than two years after the end of the accounting period.