Commencement and transitional provisionU.K.
21U.K.The amendments made by this Schedule are treated as having come into force on 1 January 2013.
22(1)Section 371CE of TIOPA 2010 (as amended by paragraph 17 above) applies for accounting periods of CFCs beginning before 20 March 2013 with the modifications set out in this paragraph. References below to subsections are to subsections of section 371CE.U.K.
Accounting periods ending before 20 March 2013
(2)For accounting periods ending before 20 March 2013, subsection (4) applies as if paragraph (b) were omitted.
Accounting periods ending on or after 20 March 2013
(3)The following sub-paragraphs apply for accounting periods ending on or after 20 March 2013.
(4)A notice may be given under subsection (2)(b) even though the requirement of subsection (2)(a) is not met.
(5)If a notice is given under subsection (2)(b) in a case where the requirement of subsection (2)(a) is not met, the CFC's trading finance profits are to be apportioned on a just and reasonable basis between—
(a)the part of the accounting period falling before 20 March 2013 (“period A”), and
(b)the remaining part of the accounting period (“period B”).
(6)So far as the CFC's trading finance profits are apportioned to period A, they are to be treated as non-trading finance profits if the CFC is a group treasury company in period A (and subsection (3) applies to them accordingly).
(7)For the purpose of determining if the CFC is a group treasury company in period A, subsection (4) applies—
(a)as if references to the accounting period were to period A, and
(b)as if paragraph (b) were omitted.
(8)So far as the CFC's trading finance profits are apportioned to period B, they are to be treated as non-trading finance profits if the CFC is a group treasury company in period B (and subsection (3) applies to them accordingly).
(9)For the purpose of determining if the CFC is a group treasury company in period B, subsection (4) applies as if references to the accounting period were to period B.