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Corporation Tax Act 2010

Section 685: Apportionment of amounts

2127.This section stipulates how various amounts are to be apportioned for the purposes of this Chapter. It is based on section 768E of, and paragraphs 6, 7 and 8 of Schedule 28A to, ICTA.

2128.The source legislation obliges the reader to tally sub-paragraphs of paragraph 6 of Schedule 28A to ICTA with sub-paragraphs of paragraph 7(1) of that Schedule. This is inconvenient, as the sub-paragraphs are not always in one-to-one correspondence and the legislation has been amended several times. Paragraphs 6 and 7(1) of that Schedule have therefore been rewritten in subsection (2) as a two-column table.

2129.Detailed comments on the table are given below.

RowOrigin
1 and 2Paragraphs 6(da) and 7(1)(c) of Schedule 28A to ICTA. In rows 1 and 2, the opportunity has been taken to deal with profits and deficits separately.
3Paragraphs 6(db) and 7(1)(d)(i) and (e)(i) of Schedule 28A to ICTA.
4Paragraphs 6(dc) and 7(1)(b) of Schedule 28A to ICTA.
5Paragraphs 6(de) and 7(1)(g) of Schedule 28A to ICTA.
6Paragraphs 6(df) and 7(1)(h) of Schedule 28A to ICTA.
7Paragraphs 6(a) and 7(1)(a) of Schedule 28A to ICTA.
Paragraphs 6(b) and 7(1)(aa) of Schedule 28A to ICTA are repealed as obsolete. See the commentary on the amendments made to section 768B of ICTA by Schedule 1.
8Paragraphs 6(c) and 7(1)(b) of Schedule 28A to ICTA.
9Paragraphs 6(d) and 7(1)(c) of Schedule 28A to ICTA.
10Paragraphs 6(e) and 7(1)(c) of Schedule 28A to ICTA.

2130.In rewriting paragraph 8 of Schedule 28A to ICTA, subsection (3) omits both instances of “appears”. See the commentary on section 674.

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