Taxation (International and Other Provisions) Act 2010

Part 2 Changes in the law

10 (1) This paragraph applies if, in the case of any person—

(a) a thing is done or an event occurs before 1 April 2010, and

(b) because of a change in the law made by this Act, the corporation tax consequences of that thing or event for the relevant period are different from what they would otherwise have been.

(2) This paragraph also applies if, in the case of any person—

(a) a thing is done or an event occurs before 6 April 2010, and

(b) because of a change in the law made by this Act, the income tax consequences of that thing or event for the relevant period are different from what they would otherwise have been.

(3) If the person so elects, this Act applies with such modifications as may be necessary to secure that the consequences for that tax for that period are the same as they would have been if the change in the law had not been made.

(4) In sub-paragraphs (1) and (2) “the relevant period” means—

(a) for corporation tax purposes, any accounting period beginning before and ending on or after 1 April 2010, and

(b) for income tax purposes, any period of account beginning before and ending on or after 6 April 2010.

(5) If this paragraph applies in the case of two or more persons in relation to the same thing or event, an election made under this paragraph by any one of those persons is of no effect unless a corresponding election is made by the other or each of the others.

(6) An election under this paragraph must be made—

(a) for corporation tax purposes, not later than 2 years after the end of the accounting period, and

(b) for income tax purposes, on or before the first anniversary of the 31 January following the tax year in which the period of account ends.