CTM08800 | Corporation Tax: change of ownership: companies with investment business: apportionment of ‘amounts in issue’

From HM Revenue & Customs · Company Taxation Manual

and S686

The amounts in issue for which an apportionment is required under () are listed at . The amounts, and the manner of apportionment, are as follows:

RowAmount of apportionmentMethod of apportionment
1The amount for the true accounting period (AP) of any adjusted non-trading profits from the company's loan relationships (see )Apportion on a time basis according to the respective lengths of the two notional APs
2The amount for the true AP of any adjusted non-trading deficit from the company's loan relationships (see S686 (3))Apportion on a time basis according to the respective lengths of the two notional APs
3The amount of any non-trading debit that falls to be brought into account for the true AP for the purposes of (loan relationships) in respect of any debtor relationship of the company(1) If condition A in S686 (4) is met, apportion by reference to the time of accrual of the amount to which the debit relates(2) If condition B in S686 (5) is met, apportion to the first notional AP
4The amount of any non-trading deficit carried forward to the true AP under , S463G (6) or S463H (4)Apportion the whole of the amount to the first notional AP
5The amount of any non-trading credits or debits in respect of intangible fixed assets that fall to be brought into account for the true AP under (non-trading gains and losses), but excluding any amount within 6 belowApportion to each notional AP the credits or debits that would fall to be brought into account in that period if it were a period of account for which accounts were drawn up in accordance with generally accepted accounting practice (GAAP).
6The amount of any non-trading loss on intangible fixed assets carried forward to the true AP under and treated under that section as if it were a non-trading loss on intangible fixed assets for that periodApportion the whole of the amount to the first notional AP
7The amount of any expenses of management referable to the true AP within the meaning of (companies with investment business) - but see )Apportion to each notional accounting period the amounts that would fall to be brought into account in that period as a if it were a period of account for which accounts were drawn up in accordance with generally accepted accounting practice (GAAP)
8The amount of any excess carried forward under (expenses of management carried forward) to the true APApportion the whole of the amount to the first notional AP
9The amount of any allowances falling to be made for the true AP as a result of which would (but for this provision) be added to the expenses of management for the period under (excess capital allowances)Apportion the amount on a time basis according to the respective lengths of the two notional APs
10Any other amounts by reference to which the profits or losses of the true AP would be calculatedApportion the amount on a time basis according to the respective lengths of the two notional APs

If any method of apportionment would work unjustly or unreasonably, any other method that is just and reasonable may be used