Section 676AJ | Restriction on deduction of post-1 April 2017 expenses of management

(1)This section has effect for the purpose of restricting deductions for post-1 April 2017 relevant expenses of management of the transferred company.

(2)Any amounts which—

(a)are, or are treated as, expenses of management referable to the actual accounting period, and

(b)are apportioned to either of the two notional accounting periods in accordance with section 685,

are treated for the purposes of Chapter 2 of Part 16 of CTA 2009 (companies with investment business) as expenses of management referable to that notional accounting period.

(3)Any allowances which are apportioned to either of the notional accounting periods in accordance with section 685 are treated for the purposes of section 253 of CAA 2001 and section 1233 of CTA 2009 (companies with investment business: excess capital allowances) as falling to be made in that notional accounting period.

(4)In calculating the taxable total profits of an accounting period of the transferred company ending after the change in ownership—

(a)relevant expenses of management, and

(b)relevant allowances,

may not be deducted from affected profits of the accounting period.

(5)In this section “relevant expenses of management” means expenses of management which are first deductible under section 1219 of CTA 2009 for an accounting period beginning—

(a)on or after 1 April 2017, and

(b)before the change in ownership.

(6)In this section “relevant allowances” means allowances falling to be made for an accounting period beginning—

(a)on or after 1 April 2017, and

(b)before the change in ownership.