Taxation (International and Other Provisions) Act 2010

26 (1) Despite their repeal by this Act, the saved rules have effect for the purposes of applying sections 806A to 806K of ICTA in relation to distributions paid— U.K.

(a) before 1st July 2009, but

(b) in accounting periods ending on or after 1st April 2010.

(2) In this paragraph “the saved rules” means the following provisions of ICTA—

(a) section 788(4),

(b) in section 788(5), the first two sentences,

(c) section 790(12), and

(d) section 792.

(3) The saved rules, so far as having effect as mentioned in sub-paragraph (1), have effect with the following modifications.

(4) Section 788(4) of ICTA has effect as if for “by virtue of this section” there were substituted “ under section 2(1) of TIOPA 2010 ”.

(5) In section 788(5) of ICTA the first sentence has effect as if for the words before “any amount of tax” there were substituted “ For the purposes of Chapter 2 of this Part in its application to relief under sections 2 and 6 of TIOPA 2010, but subject to section 31(4) of TIOPA 2010, ”.

(6) Section 790(12) of ICTA has effect as if for the words from the beginning to “unilateral relief,” there were substituted “ In Chapter 2 of this Part in its application to relief under section 18(1)(b) and (2) of TIOPA 2010, ”.

(7) Section 792(1) of ICTA has effect as if—

(a) for “by virtue of section 788” (in both places) there were substituted “ under section 2(1) of TIOPA 2010 ”,

(b) for “Chapter 7 of Part 3 of the Finance Act 2004” there were substituted “ Part 3 of TIOPA 2010 ”, and

(c) for “section 790” there were substituted “ section 18(1)(b) and (2) of TIOPA 2010 ”.

(8) Section 792 of ICTA has effect as if after subsection (3) there were (by way of relocation of provisions of section 790(3) of ICTA) inserted—

“(4) Any expression in this Chapter which imports a reference to relief under arrangements for the time being having effect under section 2(1) of TIOPA 2010 shall be deemed to import also a reference to unilateral relief.”