Finance Act 2006

9(1)The amendments made by this Schedule, other than those made by paragraphs 4(2) and 5, have effect—U.K.

(a)in relation to any accounting period of a claimant company beginning on or after 1st April 2006, and

(b)in relation to any period (“the loss period”) beginning on or after 1st April 2006 in which any loss or other amount arises to a non-resident company.

(2)If an accounting period (a “straddling period”) of a claimant company begins before 1st April 2006 and ends on or after that date—

(a)so much of the straddling period as falls before 1st April 2006, and

(b)so much of the straddling period as falls on or after that date,

are to be treated as separate accounting periods for the purposes of the amendments made by this Schedule other than those made by paragraphs 4(2) and 5.

(3)The amount of the claimant company's profits for the straddling period is to be attributed, on an apportionment in accordance with this paragraph, to those separate accounting periods.

(4)If the loss period of the non-resident company begins before 1st April 2006 and ends on or after that date—

(a)so much of the loss period as falls before 1st April 2006, and

(b)so much of the loss period as falls on or after that date,

are to be treated as separate periods for the purposes of the amendments made by this Schedule other than those made by paragraphs 4(2) and 5.

(5)The amount of the loss or other amount of the non-resident company for the loss period is to be attributed, on an apportionment in accordance with this paragraph, to those separate periods.

(6)Any apportionment under this paragraph is to be made on a just and reasonable basis.