Part 2: Consequential amendments
66.Paragraph 2 inserts a new Part 9E of Schedule 18 to FA 1998. This new Part contains rules for designation of relevant losses as unrestricted under new section 269CH.
67.Paragraph 3 gives effect to the carry forward of expenses of management where they are not useable because of the restriction under Part 7A. The carry-forward of trading losses and non-trading deficits denied by the restriction will happen without the need for any amendments.
68.Paragraphs 4 and 5 integrate Part 7A with the rest of CTA 2010
69.Paragraph 6 amends the controlled foreign company (CFC) provisions in Part 9A of the Taxation (International and Other Provisions) Act 2010 (TIOPA 2010) to deny relief to banking companies for pre-2015 carried-forward non-trading deficits and management expenses as part of a claim to relevant allowances under section 371UD of that Act (carried forward trading losses are already unavailable). This gives the same treatment to CFC charges of a banking company and profits arising from arrangements under the new section 269CK.
