6(1)In section 86 of TIOPA 2010 (schemes about claims or elections etc)—U.K.
(a)in subsection (1), omit “under the scheme or arrangement”, and
(b)after subsection (3) insert—
“(3A)Reference in subsection (1) to a step that is taken or not taken by a participant includes one that was taken or not taken by a participant before the scheme or arrangement was made.
(3B)The reason for taking or not taking a step does not matter so long as it has the effect mentioned in subsection (1).”
(2)The amendments made by this paragraph have effect in relation to amounts of foreign tax payable—
(a)as regards corporation tax, on or after 1 April 2010, and
(b)as regards income tax or capital gains tax, on or after 6 April 2010.