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(1)If a streaming election has effect in relation to the company sections 18M and 18N apply (instead of section 18K).
(2)For the purposes of this section “streaming election” means an election, made at the same time as the company's election under section 18A, which—
(a)states that sections 18M and 18N are to have effect in relation to the company (instead of section 18K), and
(b)specifies which of the territories that are relevant foreign territories in relation to the company are to be streamed territories for the purposes of the operation of sections 18M and 18N in relation to the company.
(3)Subject to subsection (4), a streaming election is irrevocable.
(4)A streaming election can be revoked at any time before the first relevant accounting period of the company.
(5)A streaming election does not have effect unless the company, in the company tax return for the first relevant accounting period of the company, specifies how much of the amount eligible to be streamed to each streamed territory is to constitute for the purposes of sections 18M and 18N the streamed opening negative amount at the beginning of that relevant accounting period.
(6)For the purposes of subsection (5) the amount eligible to be streamed to a territory by the company is the amount that would be the total opening negative amount of the company at the beginning of the first relevant accounting period of the company if at all material times the territory were the only relevant foreign territory in relation to the company.]
Textual Amendments
F1Pt. 2 Ch. 3A inserted (19.7.2011) by Finance Act 2011 (c. 11), Sch. 13 paras. 4, 31
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