Part 14

Change in company ownership
CHAPTER 2C

Disallowance of group relief for carried-forward losses: general provision

“Affected profits”
676CG
1
This section has effect for the purposes of section 676CF.
2
Profits of an accounting period ending after the change in ownership are “affected profits” if and so far as—
a
they arise before the 5th anniversary of the end of the accounting period of the transferred company in which the change in ownership occurs, and
b
they can fairly and reasonably be attributed to activities, or other sources of income, as a result of which, or partly as a result of which, the major change mentioned in section 673(4), 676AA(3) or 677(3) (as the case may be) has occurred.
3
If an accounting period of the company in relation to which the major change mentioned in section 673(4), 676AA(3) or 677(3) has occurred begins before, and ends after, the anniversary mentioned in subsection (2), then for the purposes of that subsection—
a
the accounting period is treated as two separate accounting periods, the first ending with that date and the second consisting of the remainder of the period, and
b
the profits or losses of the accounting period are apportioned to the two periods.
4
Any apportionment under subsection (3)(b) is to be made on a time basis according to the respective lengths of the two deemed accounting periods.
5
But if that method of apportionment would work unjustly or unreasonably in any case, such other method is to be used as is just and reasonable.
Pt. 14 Ch. 2C inserted (with effect in accordance with Sch. 4 para. 190 of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 4 para. 77
Pt. 14 applied (1.4.2022 in relation to accounting periods beginning on or after that date) by Finance Act 2022 (c. 3), s. 51(1), Sch. 7 para. 20
Pt. 14 applied (with modifications) (14.7.2022) by Energy (Oil and Gas) Profits Levy Act 2022 (c. 40), Sch. 1 para. 18 (with ss. 15(1), 16(1), 17)