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10.—(1) This regulation applies if—
(a)an insurance company makes an election under section 18A of the Corporation Tax Act 2009, and
(b)at that time the full amount of the receipts or expenses within regulation 5 of the business has not been treated as arising to the company.
(2) The remaining amount of the receipts or expenses which relate to the business of the permanent establishment are treated as arising to the company in the accounting period—
(a)in which the election is made, or
(b)if section 18F(4) of the Corporation Tax Act 2009(1) applies, in the accounting period ending immediately before the relevant day (within the meaning of that section).
(3) If it is necessary to apportion any amount to determine the amount in paragraph (2), such apportionment must be on a just and reasonable basis.
Section 18F was inserted by paragraph 4 of Schedule 13 to the Finance Act 2011.
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