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HMRC internal manual

Company Taxation Manual

From
HM Revenue & Customs
Updated
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Corporation Tax: change of ownership: companies with investment business: apportionment between notional accounting periods

CTA2010/S702

The rules for apportioning are the same as those for CTA2010/S677 (CTM08800) with the addition of provision for the apportionment of the amount to be included in respect of chargeable gains.

  • If the amount to be included does not exceed the amount of the ‘relevant gain’ (CTM08880), the whole amount is apportioned to the notional period beginning with the change in ownership.
  • If it exceeds the relevant gain, the excess is apportioned to the notional accounting period ending with the change in ownership and the relevant gain to the notional accounting period beginning with the change.