Section 105 of CTA 2010 (restriction on surrender of losses etc within section 99(1)(d) to (g)) is amended as follows.
In subsection (2), for "the surrendering company's gross profits of the surrender period" substitute ." the profit-related threshold "
In subsection (3), for "those gross profits" substitute ." the profit-related threshold "
After subsection (3) insert—
After subsection (5) insert—
The amendments made by this section have effect where the surrender period of the surrendering company ends on or after 20 March 2013, but subject to the following.
For the purposes of section 105(3A)(b) and (3B)(b) of CTA 2010, chargeable profits do not include—
Subsection (9) applies where—
falls partly before and partly on or after 20 March 2013.
For the purposes of section 105 of CTA 2010, the chargeable profits of the CFC for that period, so far as apportioned to the surrendering company as mentioned in subsection (3A)(b) or (3B)(b) of that section (as the case requires), are to be further apportioned on a just and reasonable basis between the two parts of the period, and the chargeable profits referred to in subsection (3A)(b) or (3B)(b) are not to include the chargeable profits apportioned to the part ending before 20 March 2013.