7(1)Where a controlled foreign company has an accounting period (“the straddling accounting period”) that—U.K.
(a)begins before 1 July 2009, and
(b)ends on or after that date,
the straddling accounting period is to be treated as split.
(2)Where this paragraph provides that the straddling accounting period is to be treated as “split”—
(a)that part of the straddling accounting period that falls before 1 July 2009 and that part of the straddling accounting period that falls on or after that date are to be treated for the purposes of Chapter 4 of Part 17, and Part 18, of ICTA[F1and Part 2 of TIOPA 2010] as separate accounting periods, and
(b)the company's chargeable profits for the straddling accounting 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.
Textual Amendments
F1Words in Sch. 16 para. 7(2)(a) inserted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 8 para. 104 (with Sch. 9 paras. 1-9, 22)