Part 22Miscellaneous provisions

Chapter 2Transfers of trade to obtain balancing allowances

956Apportionment if part of trade treated as separate trade

1

If part of a trade is to be treated as a separate trade in accordance with section 954(6) or 955(7), just and reasonable apportionments are to be made of receipts, expenses, assets and liabilities.

2

Subsection (3) applies if—

a

at the time of an apportionment under subsection (1) it appears that the apportionment is material to the liability to tax (for whatever period) of two or more companies, and

b

a question arises as to how the apportionment is to be made for the purposes of the liability of those companies.

3

The question is to be determined in the same way as an appeal, and all the companies concerned are entitled to be a party to the proceedings.