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Legislation
Corporation Tax Act 2010

Part 21B Group mismatch schemes

  • Section 938A Losses and profits from group mismatch schemes to be disregarded
  • Section 938B Meaning of “a group mismatch scheme” and “the scheme group”
  • Section 938C Meaning of “scheme loss” and “scheme profit”
  • Section 938D Meaning of “relevant tax advantage” etc and “the scheme period”
  • Section 938E Meaning of “group”
  • Section 938F Meaning of references to economic profits and losses
  • Section 938G Tax capacity assumption
  • Section 938H Meaning of “scheme”
  • Section 938I Schemes involving repos or quasi-repos
  • Section 938J Schemes involving finance arrangements
  • Section 938K Trading income
  • Section 938L Foreign companies and foreign permanent establishments
  • Section 938M Controlled foreign companies
  • Section 938N Priority
  1. Part 21B
  2. Meaning of references to economic profits and losses

Section 938F | Meaning of references to economic profits and losses

From legislation.gov.uk

(1)An economic profit or loss is to be computed for the purposes of this Part taking into account, in particular—

(a)profits and losses made as a result of the operation of the Corporation Tax Acts, and

(b)any adjustments required to reflect the time value of money.

(2)A reference in this Part to an economic profit or loss made by the scheme group over the scheme period is to an economic profit or loss made in that period by the members of the group considered together.

(3)In determining for the purposes of this Part the amount of an economic profit or loss made by the scheme group over the scheme period, profits and losses made by a member of the group are to be taken into account only to the extent that they are attributable to times at which the member is a party to the scheme.

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