TIOPA 2010U.K.
175U.K.TIOPA 2010 is amended as follows.
176U.K.In section 54 (double taxation relief by way of credit: non-trading debits on loan relationships) in subsection (7)—
(a)in paragraph (b) of the definition of “carry-back claim”, after “459(1)(b)” insert “ or 463B(1)(b) ”,
(b)in paragraph (b) of the definition of “carry-forward provision”, after “457(1)” insert “ , 463G(5) or 463H(4) ”, and
(c)in paragraph (b) of the definition of “current-year provision or claim”, after “459(1)(a)” insert “ or 463B(1)(a) ”.
177U.K.In section 55 (double taxation relief by way of credit: current year's non-trading deficits on loan relationships)—
(a)in subsection (4)(b), after “459(1)(a)” insert “ or 463B(1)(a) ”, and
(b)in subsection (5), for “or 459(1)(a)” substitute “ , 459(1)(a) or 463B(1)(a) ”.
178U.K.In section 156(1) (meaning of “losses” in Part 4)—
(a)in paragraph (e) after “Chapter 16” insert “ or Chapter 16A ”,
(b)omit “or” at the end of paragraph (f), and
(c)after paragraph (g) insert “, or
(h)Part 5A of CTA 2010 (group relief for carried-forward losses).”
179U.K.In section 371IF (determining the profits of a CFC's qualifying loan relationship), in paragraph (b) of step 5, after “16” insert “ or Chapter 16A ”.
180U.K.After section 371SK insert—
“371SKARestrictions on certain deductions: deductions allowances
(1)This section applies for the purposes of—
(a)applying Part 7ZA of CTA 2010 (restrictions on obtaining certain deductions), and
(b)applying any provision of Part 7ZA of CTA 2010 for the purposes of Part 7A of that Act (restrictions on obtaining certain deductions: banking companies).
(2)Assume that each of the following is nil—
(a)the CFC's deductions allowance for the relevant accounting period,
(b)the CFC's trading profits deductions allowance for the relevant accounting period, and
(c)the CFC's non-trading profits deductions allowance for the relevant accounting period.
(3)But if section 269ZX of CTA 2010 (increase of deductions allowance where provision for onerous lease reversed) applies in relation to the relevant accounting period, the reference in subsection (2) to “nil” is to be read as a reference to an amount equal to the increase provided for by subsection (3) of that section.”
181U.K.In subsection (2)(a) of section 371SL (group relief etc)—
(a)after “(group relief)” insert “ or Part 5A of that Act (group relief for carried-forward losses) ”, and
(b)after “by way of group relief” insert “ or group relief for carried-forward losses ”.