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38In section 398D (restriction on use of losses) for subsection (6) substitute—
“(6)Subsection (6A) applies if A is a CFC within the meaning of Part 9A of TIOPA 2010 and the CFC charge is charged in relation to the accounting period ending with the relevant day.
(6A)No sum may be set off under section 371UD of TIOPA 2010 against the sum charged on a chargeable company so far as the sum charged is attributable to the CFC’s chargeable profits so far as, in turn, attributable to the carrying on of the relevant activity.”
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