7(1)The amendments made by paragraphs 1 to 5 of this Schedule have effect for the purposes of calculating the taxable total profits of companies for accounting periods beginning on or after 1 April 2015.U.K.
(2)But section 269CK of CTA 2010 (inserted by this Schedule) does not have effect in relation to any arrangements made before 3 December 2014.
(3)Sub-paragraph (4) applies where a company has an accounting period beginning before 1 April 2015 and ending on or after that date (“the straddling period”).
(4)For the purposes of Chapter 3 of Part 7A of CTA 2010—
(a)so much of the straddling period as falls before 1 April 2015, and so much of that period as falls on or after that date, are treated as separate accounting periods, and
(b)the profits or losses of the company for the straddling period are apportioned to the two separate accounting periods—
(i)in accordance with section 1172 of CTA 2010 (time basis), or
(ii)if that method would produce a result that is unjust or unreasonable, on a just and reasonable basis.