Corporation Tax Act 2010

Transactions in securities: general

84 (1) Part 15 (transactions in securities), so far as relating to the counteraction of corporation tax advantages, applies—

(a) whether or not the transaction or transactions in consequence of which, or of the combined effect of which, the tax advantage has been or will be obtained occur on or after 1 April 2010, and

(b) whether or not that advantage relates to an accounting period ending on or after that date.

(2) Sub-paragraph (1) does not affect section 746(5) (under which no assessments may be made as a result of a counteraction notice later than 6 years after the accounting period to which the tax advantage relates).

(3) No notification under section 703(9) of ICTA (notification that the Commissioners for Her Majesty’s Revenue and Customs have reason to believe that section 703 applies to a company in respect of one or more specified transactions) may be given on or after 1 April 2010.

(4) If notification under section 703(9) of ICTA has been given before that date, Chapter 1 of Part 17 of that Act (cancellation of corporation tax advantages from certain transactions in securities) continues to apply in relation to the cancellation of any tax advantage resulting from the transaction or transactions specified in the notification, regardless of the date on which any accounting period to which the tax advantage relates ends.

(5) This paragraph is to be interpreted as if it were part of Part 15.