SCHEDULE 24ASSUMPTIONS FOR CALCULATING CHARGEABLE PROFITS, CREDITABLE TAX AND CORRESPONDING UNITED KINGDOM TAX OF FOREIGN COMPANIES
Capital allowancesF1 and expenditure on car hire
10
(1)
F2Subject to paragraph 12 below, if, in an accounting period falling before the beginning of the first accounting period—
(b)
which is an ADP exempt period,
the company incurred any capital expenditure on the provision of F5plant or machinery for the purposes of its trade, that plant or machinery shall be assumed, for the purposes of Part 2 of the Capital Allowances Act, to have been provided for purposes wholly other than those of the trade and not to have been brought into use for the purposes of that trade until the beginning of that first accounting period, and F6section 13 of that Act (use for qualifying activity of plant or machinery provided for other purposes) shall apply accordingly.
(2)
This paragraph shall be construed as one with F7Part 2 of the Capital Allowances Act.
11
F8. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
11A
(1)
This paragraph applies where by virtue of section 747A the company’s chargeable profits for an accounting period (the period in question) are to be computed and expressed in a currency (the relevant foreign currency) other than sterling.
(2)
For the purposes of making in relation to the period in question any calculation which—
(a)
falls to be made under the enactments relating to capital allowances, and
(b)
takes account of amounts arrived at under those enactments in relation to accounting periods falling before the company’s commencement day (within the meaning given by section 747A(9)),
it shall be assumed that any such amount is the equivalent, expressed in the relevant foreign currency, of the amount expressed in sterling.
(3)
F9. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(4)
For the purposes of the application of F10section 578A or 578B or section 74(2), 75(1), 76(2), (3) or (4) or 511(3) of the Capital Allowances Act (motor cars and dwelling-houses) in relation to expenditure incurred in the period in question, it shall be assumed that any sterling sum mentioned in any of those sections is the equivalent, expressed in the relevant foreign currency, of the amount expressed in sterling.
(5)
The translation required by sub-paragraph (2) above shall be made by reference to the London closing exchange rate for the two currencies concerned for the first day of the period in question.
(6)
F9. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(7)
The translation required by sub-paragraph (4) above shall be made by reference to the London closing exchange rate for the two currencies concerned for the day on which the expenditure concerned was incurred.