Skip to content
Solved

CTM08910 | Corporation Tax: change of ownership: companies with investment business: apportionment between notional accounting periods

From HM Revenue & Customs · Company Taxation Manual

The rules for apportioning are the same as those for CTA10/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 accounting period (AP) beginning with the change in ownership.

  • If it exceeds the relevant gain, the excess is apportioned to the notional AP ending with the change in ownership and the relevant gain to the notional AP beginning with the change.