29 Restriction on surrender of losses: controlled foreign company cases
Finance Act 2013 (2013 c 29) | Legislation

Chapter 3
Corporation Tax: General

Losses, other reliefs and deductions

29  Restriction on surrender of losses: controlled foreign company cases

(1)     Section 105 of CTA 2010 (restriction on surrender of losses etc within section 99(1)(d) to (g)) is amended as follows.

(2)     In subsection (2), for “the surrendering company's gross profits of the surrender period†substitute “the profit-related thresholdâ€.

(3)     In subsection (3), for “those gross profits†substitute “the profit-related thresholdâ€.

(4)     After subsection (3) insert—

“(3A)     The profit-related threshold†is the sum of—

(a)     the surrendering company's gross profits of the surrender period, and

(b)     where chargeable profits of a CFC for an accounting period ending in the surrender period are apportioned to the surrendering company in accordance with step 3 in subsection (1) of 371BC of TIOPA 2010

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