If, in the case of a reference period (“RP1”) of a company, the amount mentioned in subsection (1)(b) of section 356GB exceeds the amount mentioned in subsection (1)(a) of that section, an amount equal to the difference between those amounts is treated as onshore allowance held by the company for the site concerned for the next period.

If RP1 is immediately followed by another reference period of the company (belonging to the same site), “the next period” means that reference period.

If subsection (2) does not apply, “the next period” means the next accounting period of the company.