SCHEDULES

SCHEDULE 7Hybrid and other mismatches

PART 15Commencement

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1

Part 6 of this Schedule (allocation of dual inclusion income within group) has effect in relation to accounting periods of a claimant company that begin on or after 1 January 2021.

2

A “claimant company” is a company that makes an allocation claim for the purposes of Chapter 12A of Part 6A of TIOPA 2010 (inserted by Part 6 of this Schedule).

3

For the purposes of sub-paragraph (1), where there is a straddling period—

a

so much of the straddling period as falls before 1 January 2021, and so much of it as falls on or after that date, are to be treated as separate accounting periods, and

b

if it is necessary to apportion an amount for the straddling period to the two separate periods, it is to be apportioned—

i

on a time basis, according to the respective length of the separate periods, or

ii

if that would produce a result that is unjust or unreasonable, on a just and reasonable basis.

4

A “straddling period” is an accounting period beginning before 1 January 2021 and ending on or after that date.