Amendment of the Income and Corporation Taxes Act 1988
6.—(1) Amend section 432D (section 432B apportionment: value of non-participating funds)(1) as follows.
(2) In subsection (3)—
(a)in paragraph (a) after “so far as referable to the category” insert “(but taking that mean to be nil if it would otherwise be below nil)”;
(b)at the end insert “This is subject to subsection (3A) below.”
(3) After subsection (3) insert—
“(3A) If the denominator found in accordance with subsection (3)(b) above is nil then, for the purposes of subsection (2) above, “the relevant fraction” in relation to a category of business is such fraction as is just and reasonable.”.
Section 432D was relevantly amended by paragraph 15(4) of Schedule 8 to the Finance Act 1995 (c. 4) and section 109(3) and (4) of the Finance Act 2000.