OT62040 | Transferable tax history - Effect of a TTH election on the seller - Functional Currency

Ring fence profits and adjusted ring fence profits that are transferred in accordance with a TTH election must be in sterling. Where a buyer has a functional currency other than sterling, and sets a loss against the transferred profits from the TTH election, the normal rules in CTA2009\S12 apply, as if the buyer’s functional currency in the earlier period had been sterling.