10(1)The amendments made by this Schedule have effect in relation to accounting periods of controlled foreign companies beginning on or after 6th December 2006.U.K.
(2)In the case of an accounting period (a “straddling period”) of a controlled foreign company—
(a)beginning before 6th December 2006, and
(b)ending on or after that date,
the amendments made by this Schedule have effect as if, for the purposes of Chapter 4 of Part 17 of ICTA, so much of the straddling period as falls before that date, and so much of the straddling period as falls on or after that date, were separate accounting periods.
(3)The company's chargeable profits for the straddling period, and its creditable tax (if any) for that period, are to be apportioned to the two separate accounting periods on a just and reasonable basis.
(4)Each of the following expressions—
“accounting period”,
“chargeable profits”,
“controlled foreign company”, and
“creditable tax”,
has the same meaning in this paragraph as in Chapter 4 of Part 17 of ICTA.