Finance Act 2010

(937A) This Part contains rules about the treatment of certain losses made by companies as a result of risk transfer schemes. (937B) (1) A risk transfer scheme may be— (a) a group scheme, or (b) a risk transfer scheme other than a group scheme (a “single-company scheme”). (2) A risk transfer scheme to which a company (“company A”) is a party is a “group scheme” if at least one company other than company A is at any time both— (a) associated with company A, and (b) a party to the scheme. (3) In this Part “the relevant group” means— (a) company A, and (b) each company other than company A in relation to which the condition in subsection (2) is met. (4) In its application in relation to single company schemes, this Part applies subject to the following modifications. (5) The modifications are that— (a) references to the relevant group, a member of the relevant group, or the members of the relevant group, are treated as references to company A, and (b) sections 937E(2) and 937L(2) are treated as omitted. (937C) (1) A scheme to which a company (“company A”) is a party is a “risk transfer scheme” if conditions 1 to 3 are met. (2) Condition 1 is that the purpose, or one of the main purposes, of any member of the relevant group on entering into the scheme is to obtain a financial advantage for the relevant group that it is reasonable to assume could not otherwise have been obtained without the relevant group becoming subject to (or incurring the cost of avoiding) a relevant risk. (3) In subsection (2) “a relevant risk” means a risk that the relevant group would make economic losses in one or more accounting periods of company A as a result of fluctuations in— (a) the rate of exchange between any two currencies, (b) the retail prices index (or any similar general index of prices) or any other index, or (c) any price or other value. (4) Condition 2 is that, as a result of the scheme, and disregarding the effect of this Part, the relevant group— (a) is not subject to the relevant risk, or (b) is subject only to a negligible proportion of that risk. (5) Condition 3 is that, disregarding the effect of the provisions of the Corporation Tax Acts, condition 2 would not be met. (6) For the purposes of this section the relevant group obtains a “financial advantage” from a scheme if, taking into account the effect of the scheme on each member of the group, the scheme— (a) increases the return on any investment, (b) reduces the costs of any borrowing, or (c) has an effect economically equivalent to that mentioned in paragraph (a) or (b). (937D) In this Part “the scheme rate, index or value”, in relation to a risk transfer scheme, means the rate, index or value mentioned in section 937C(3)(a), (b) or (c) in relation to the relevant risk for the scheme. (937E) (1) A loss or profit made by a company in an accounting period is a “scheme loss” or “scheme profit” in relation to a risk transfer scheme to which the company is a party at any time in the period if the loss or profit— (a) is from a loan relationship, or derivative contract, that is part of the scheme, (b) would, apart from this Part, be brought into account in determining a debit or credit for the purposes of Part 5 of CTA 2009 (loan relationships) or Part 7 of that Act (derivative contracts), and (c) arises as a result of fluctuations in the scheme rate, index or value. (2) References in this Part to a scheme loss or scheme profit made by a company in a period that is not an accounting period of that company are to the scheme loss or scheme profit that the company would have made in the period from the loan relationship or derivative contract in question if the period had been an accounting period of the company. (3) References in this section to a loss or profit from a loan relationship or a derivative contract include— (a) a loss or profit from a related transaction, and (b) a loss or profit of a capital nature. (4) In subsection (3)(a) “related transaction” has the meaning given by— (a) section 304 of CTA 2009 (in relation to a loan relationship), or (b) section 596 of that Act (in relation to a derivative contract). (937F) (1) Subsection (2) applies if— (a) a company makes one or more scheme losses in an accounting period in relation to a risk transfer scheme, and (b) disregarding any profits or losses made otherwise than as a result of the scheme, the relevant group makes a pre-tax economic loss in the period as a result of fluctuations in the scheme rate, index or value. (2) The relevant proportion of each scheme loss made by the company in the accounting period is a “ring-fenced scheme loss”. (3) For this purpose “the relevant proportion” means— $$A–B–CA$where—A is the total of the scheme losses made in the period in relation to the scheme by the members of the relevant group,B is the total of the scheme profits made in the period in relation to the scheme by the members of the relevant group, andC is the pre-tax economic loss referred to in subsection (1)(b).$ (4) Subsection (5) applies if— (a) a company makes one or more scheme profits in an accounting period in relation to a risk transfer scheme, and (b) disregarding any profits or losses made otherwise than as a result of the scheme, the relevant group makes a pre-tax economic profit in the period as a result of fluctuations in the scheme rate, index or value. (5) The relevant proportion of each scheme profit made by the company in the accounting period is a “relevant scheme profit”. (6) For this purpose “the relevant proportion” means— $$A–B–CA$where—A is the total of the scheme profits made in the period in relation to the scheme by the members of the relevant group,B is the total of the scheme losses made in the period in relation to the scheme by the members of the relevant group, andC is the pre-tax economic profit referred to in subsection (4)(b).$ (937G) (1) This section applies for the purpose of determining the amount (if any) of a ring-fenced scheme loss that may be brought into account by a company in the accounting period in which it is made. (2) If the amount of the company's profits pool for the scheme as at the beginning of the period is nil, the ring-fenced scheme loss may not be brought into account. (3) If the amount of the company's profits pool for the scheme as at the beginning of the period is— (a) greater than nil, and (b) less than the total of the ring-fenced scheme losses made in the period in relation to the scheme by the company, only the relevant proportion of the ring-fenced scheme loss may be brought into account. (4) For this purpose “the relevant proportion” means— $$AB$where—A is the amount of the company's profits pool as at the beginning of the period, andB is the total of the ring-fenced scheme losses made in the period in relation to the scheme by the company.$ (5) If the amount of the company's profits pool for the scheme as at the beginning of the period is equal to or greater than the total of the ring-fenced scheme losses made in the period in relation to the scheme by the company, the ring-fenced scheme loss may be brought into account in full. (6) A reference in this paragraph to bringing a ring-fenced scheme loss into account is to bringing it into account in determining a debit or credit for the purposes of Part 5 of CTA 2009 (loan relationships) or Part 7 of that Act (derivative contracts). (937H) (1) This section applies where— (a) a company makes one or more scheme profits in an accounting period in relation to a risk transfer scheme, (b) disregarding any profits or losses made otherwise than as a result of the scheme, the relevant group makes a pre-tax economic profit in the period as a result of fluctuations in the scheme rate, index or value, and (c) the amount of the company's losses pool for the scheme as at the beginning of the period is greater than nil. (2) The company may bring into account, as if it were a loss made in the period from a loan relationship— $$A×B$where—A is so much of the amount of the company's losses pool as at the beginning of the period as does not exceed the total of the relevant scheme profits made in the period in relation to the scheme by the company, andB is the proportion of the total of the relevant scheme profits made in the period in relation to the scheme by the company that consists of profits made from its loan relationships.$ (3) The company may bring into account, as if it were a loss made in the period from a derivative contract— $$A×C$where—A has the same meaning as in subsection (2), andC is the proportion of the total of the relevant scheme profits made in the period in relation to the scheme by the company that consists of profits made from its derivative contracts.$ (4) A reference in this section to bringing an amount into account is to bringing it into account in determining a debit or credit for the purposes of Part 5 of CTA 2009 (loan relationships) or Part 7 of that Act (derivative contracts). (937I) (1) The amount of a company's losses pool for a risk transfer scheme as at the beginning of an accounting period (“the current accounting period”) is— $$A+B–C$where—A is—the amount of the pool as at the beginning of the previous accounting period, orif the risk transfer scheme began in the current accounting period, nil,B is the total amount, if any, of ring-fenced scheme losses made in the previous accounting period in relation to the scheme by the company that, as a result of the application of section 937G(2) or (3), are not brought into account in that period, andC is the total amount (if any) that, as a result of the application of section 937H(2) or (3), is brought into account in the previous accounting period in relation to the scheme by the company.$ (2) The amount of a company's profits pool for a risk transfer scheme as at the beginning of an accounting period (“the current accounting period”) is— $$A+B–C$where—A is—the amount of the pool as at the beginning of the previous accounting period, orif the risk transfer scheme began in the current accounting period, nil,B is—the total of any relevant scheme profits made in the previous accounting period in relation to the scheme by the company, lessthe total amount (if any) that, as a result of the application of section 937H(2) or (3), is brought into account in that accounting period in relation to the scheme by the company, andC is the total amount (if any) of ring-fenced scheme losses made in the previous accounting period in relation to the scheme by the company that, as a result of the application of section 937G(3) or (5), are brought into account in that period.$ (937J) (1) This section applies for the purpose of determining whether condition 2 in section 937C is met. (2) Where a member of the relevant group (“the company”) makes a scheme loss in an accounting period, the economic profits and losses made by the relevant group in the period must be calculated on the assumption that the company obtained the full tax benefit of the loss. (3) The “full tax benefit” of the loss is the reduction in the corporation tax liability of the company that would result if— (a) the loss were brought into account, and (b) the company's profits chargeable to corporation tax, before doing so, were equal to the debit (or the reduction in any credit) determined by reference to the loss. (4) A reference in this section to bringing a loss into account is to bringing it into account in determining a debit or credit for the purposes of Part 5 of CTA 2009 (loan relationships) or Part 7 of that Act (derivative contracts). (937K) (1) For the purposes of this Part a company (“company B”) is associated with another company (“company A”) at a time (“the relevant time”) if any of the following five conditions is met. (2) The first condition is that the financial results of company A and company B, for a period that includes the relevant time, meet the consolidation condition. (3) The second condition is that there is a connection between company A and company B for the accounting period of company A in which the relevant time falls. (4) The third condition is that, at the relevant time, company A has a major interest in company B or company B has a major interest in company A. (5) The fourth condition is that— (a) the financial results of company A and a third company, for a period that includes the relevant time, meet the consolidation condition, and (b) at the relevant time the third company has a major interest in company B. (6) The fifth condition is that— (a) there is a connection between company A and a third company for the accounting period of company A in which the relevant time falls, and (b) at the relevant time the third company has a major interest in company B. (7) In this section the financial results of any two companies for any period meet “the consolidation condition” if— (a) they are required to be comprised in group accounts prepared under section 399 of the Companies Act 2006 (duty of certain parent companies to prepare group accounts), or (b) they would be required to be comprised in such accounts but for the application of an exemption mentioned in subsection (3) of that section. (8) The following provisions apply for the purposes of this section— - sections 466 to 471 of CTA 2009 (companies connected for accounting period), and - sections 473 and 474 of CTA 2009 (meaning of “major interest”). (937L) (1) A reference in this Part to an “economic” loss or profit made by any person in a period is to a loss or profit made by that person in that period, computed taking into account unrealised (as well as realised) losses and profits. (2) For the purposes of this Part an economic loss or profit is made “by the relevant group” if it is made by the members of the relevant group considered together. (3) Where— (a) any member of the relevant group makes a scheme loss or profit in an accounting period, and (b) that scheme loss or profit is, under generally accepted accounting practice, calculated by reference to fluctuations in the scheme rate, index or value over a longer period, the economic loss or profit made by the group in the accounting period as a result of those fluctuations is, so far as it relates to that scheme loss or profit, to be computed over that longer period. (4) In determining for the purposes of this Part the amount of an economic loss or profit made by the relevant group in any period, the economic losses and profits of each member of the relevant group— (a) are (subject to subsection (3)) to be computed over that period (whether or not that period is an accounting period of the member), but (b) are only to be taken into account to the extent that they are attributable to times at which the member is a party to the risk transfer scheme in question. (5) A reference in this Part to a “pre-tax” economic loss or profit is a reference to an economic loss or profit determined disregarding any loss or gain made as a result of the operation of any provision of the Corporation Tax Acts. (937M) (1) In determining under this Part amounts that a company may or may not bring into account in an accounting period, economic losses and profits are to be computed in the tax calculation currency of that company in that accounting period. (2) Section 17(5) of CTA 2010 (meaning of references to the tax calculation currency of a company) applies for the purposes of this section. (937N) In this Part “scheme” includes any scheme, arrangements or understanding of any kind whatever, whether or not legally enforceable, involving a single transaction or two or more transactions. (937O) (1) The Treasury may by order amend any enactment contained in this Part so as to apply (with or without modifications) the rules in this Part about scheme losses and scheme profits to losses and profits made in a trade. (2) The power conferred by subsection (1) may only be exercised in relation to losses and profits made by a company that carries on a banking business, an insurance business or a business consisting wholly or partly of dealing in securities. (3) In this section “securities” includes— (a) shares, (b) rights of unit holders in unit trust schemes to which TCGA 1992 applies as a result of section 99 of that Act, and (c) in the case of a company with no share capital, interests in the company possessed by members of the company. (4) An order under this section— (a) may make different provision for different cases or purposes, and (b) may include incidental, consequential, supplementary or transitional provision.

4

In Schedule 4 (index of defined expressions), insert at the appropriate places—

associated with (in Part 21A)	section 937K”
“economic loss (in Part 21A)	section 937L”
“economic profit (in Part 21A)	section 937L”
“the relevant group (in Part 21A)	section 937B(3)”
“relevant scheme profit (in Part 21A)	section 937F”
“ring-fenced scheme loss (in Part 21A)	section 937F”
“risk transfer scheme (in Part 21A)	section 937C”
“scheme (in Part 21A)	section 937N”
“scheme loss (in Part 21A)	section 937E”
“scheme profit (in Part 21A)	section 937E”
“the scheme rate, index or value (in Part 21A)	section 937D

Commencement and transitional provision

5

• (1) The amendments made by this Schedule have effect in relation to accounting periods that begin on or after 1 April 2010 (“the commencement date”).

• (2) Where a company has an accounting period (“the straddling accounting period”) that—

• (a) begins before the commencement date, and

• (b) ends on or after that date,

the straddling accounting period is to be treated as split.

• (3) Where this paragraph provides that the straddling accounting period is to be treated as split, that part of the straddling accounting period that falls before the commencement date and that part of the straddling accounting period that falls on or after that date are to be treated for the purposes of the amendments made by this Schedule as separate accounting periods.

• (4) In relation to the first accounting period of a company in relation to which the amendments made by this Schedule have effect—

• (a) section 937I of CTA 2010 (as inserted by paragraph 3 above) does not apply, and

• (b) as at the beginning of the period, the amounts of the company's losses pool and profits pool for any risk transfer scheme to which the company is a party is nil.

SCHEDULE 17

Introduction

1

Part 7 of FA 2004 (disclosure of tax avoidance schemes) is amended as follows.

Initial marketing

2

• (1) Section 307 (meaning of “promoter”) is amended as follows.

• (2) In paragraph (a) of subsection (1), for the words from “business” to “makes” substitute “business, the person (“P”)—

(i) is to any extent responsible for the design of the proposed arrangements, (ii) makes a firm approach to another person (“C”) in relation to the notifiable proposal with a view to P making the notifiable proposal available for implementation by C or any other person, or (iii) makes

.

• (3) In paragraph (b) of that subsection, after “(a)(ii)” insert “ or (iii) ”.

• (4) After subsection (1) insert—

(1A) For the purposes of this Part a person is an introducer in relation to a notifiable proposal if the person makes a marketing contact with another person in relation to the notifiable proposal.

• (5) After subsection (4) insert—

(4A) For the purposes of this Part a person makes a firm approach to another person in relation to a notifiable proposal if the person makes a marketing contact with the other person in relation to the notifiable proposal at a time when the proposed arrangements have been substantially designed. (4B) For the purposes of this Part a person makes a marketing contact with another person in relation to a notifiable proposal if— (a) the person communicates information about the notifiable proposal to the other person, (b) the communication is made with a view to that other person, or any other person, entering into transactions forming part of the proposed arrangements, and (c) the information communicated includes an explanation of the advantage in relation to any tax that might be expected to be obtained from the proposed arrangements. (4C) For the purposes of subsection (4A) proposed arrangements have been substantially designed at any time if by that time the nature of the transactions to form part of them has been sufficiently developed for it to be reasonable to believe that a person who wished to obtain the advantage mentioned in subsection (4B)(c) might enter into— (a) transactions of the nature developed, or (b) transactions not substantially different from transactions of that nature.

• (6) In subsection (5), after “promoter” insert “ or introducer ”.

• (7) In subsection (6), after “promoter” (in both places) insert “ or introducer ”.

3

• (1) Section 308(2) (duties of promoter) is amended as follows.

• (2) For “earlier” substitute “ earliest ”.

• (3) Before paragraph (a) insert—

(za) the date on which the promoter first makes a firm approach to another person in relation to a notifiable proposal,

.

4

In section 313A(1) (pre-disclosure enquiry), for “of a proposal or arrangements” substitute “ or introducer of a proposal, or the promoter of arrangements, ”.

5

In section 318(1) (interpretation), after the definition of “HMRC” insert—

“introducer”, in relation to a notifiable proposal, has the meaning given by section 307; “make a firm approach” has the meaning given by section 307(4A); “make a marketing contact” has the meaning given by section 307(4B);

.

Promoters to provide client lists

6

After section 313 insert—

(313ZA) (1) This section applies where a person who is a promoter in relation to notifiable arrangements is providing (or has provided) services to any person (“the client”) in connection with the notifiable arrangements and either— (a) the promoter is subject to the reference number information requirement, or (b) the promoter has failed to comply with section 308(1) or (3) in relation to the notifiable arrangements (or the notifiable proposal for them) but would be subject to the reference number information requirement if a reference number had been allocated to the notifiable arrangements. (2) For the purposes of this section “the reference number information requirement” is the requirement under section 312(2) to provide to the client prescribed information relating to the reference number allocated to the notifiable arrangements. (3) The promoter must, within the prescribed period after the end of the relevant period, provide HMRC with prescribed information in relation to the client. (4) In subsection (3) “the relevant period” means such period during which the promoter is or would be subject to the reference number information requirement as is prescribed. (5) The promoter need not comply with subsection (3) in relation to any notifiable arrangements at any time after HMRC have given notice under section 312(6) in relation to the notifiable arrangements.

7

In section 316 (information to be provided in manner and form specified by HMRC), for “and 313(1) and (3)” substitute “ , 313(1) and (3) and 313ZA(3) ”.

8

In section 317(2) (regulations), after “may” insert “ make different provision for different cases and may ”.

Information provided to introducers

9

After section 313B insert—

(313C) (1) Where HMRC suspect— (a) that a person (“P”) is an introducer in relation to a proposal, and (b) that the proposal may be notifiable, they may by written notice require P to provide HMRC with prescribed information in relation to each person who has provided P with any information relating to the proposal. (2) A notice must specify the proposal to which it relates. (3) P must comply with a requirement under or by virtue of subsection (1) within— (a) the prescribed period, or (b) such longer period as HMRC may direct.

Penalties

10

• (1) Section 98C of TMA 1970 (penalties for failures to comply with duties relating to disclosure of tax avoidance schemes) is amended as follows.

• (2) In subsection (1)(a) (initial penalty for failing to comply with duties), for “£5,000” substitute—

(i) in the case of a provision mentioned in paragraph (a), (b) or (c) of that subsection, £600 for each day during the initial period (but see also subsections (2A), (2B) and (2ZC) below), and (ii) in any other case, £5,000.

• (3) In subsection (2)—

• (a) omit the “and” at the end of paragraph (da),

• (b) after that paragraph insert—

(db) section 313ZA (duty of promoter to provide details of clients),

, and

• (c) insert at the end

and (f) section 313C (duty of introducer to give details of persons who have provided information).

• (4) After that subsection insert—

(2ZA) In this section “the initial period” means the period— (a) beginning with the relevant day, and (b) ending with the earlier of the day on which the penalty under subsection (1)(a)(i) is determined and the last day before the failure ceases; and for this purpose “the relevant day” is the day specified in relation to the failure in the following table.

Failure	Relevant day
A failure to comply with subsection (1) or (3) of section 308 in so far as the subsection applies by virtue of an order under section 306A	The first day after the end of the period prescribed under section 306A(6)
A failure to comply with subsection (1) or (3) of section 308 in so far as the subsection applies by virtue of an order under section 308A(2)	The first day after the end of the period prescribed under subsections (5) and (6)(a) of section 308A (as it may have been extended by a direction under subsection (6)(b) of that section)
Any other failure to comply with subsection (1) of section 308	The first day after the end of the period prescribed under that subsection
Any other failure to comply with subsection (3) of section 308	The first day after the end of the period prescribed under that subsection
A failure to comply with subsection (1) of section 309	The first day after the end of the period prescribed under that subsection
A failure to comply with section 310	The first day after the latest time by which section 310 must be complied with in the case concerned

(2ZB) The amount of a penalty under subsection (1)(a)(i) is to be arrived at after taking account of all relevant considerations, including the desirability of its being set at a level which appears appropriate for deterring the person, or other persons, from similar failures to comply on future occasions having regard (in particular)— (a) in the case of a penalty for a person's failure to comply with section 308(1) or (3), to the amount of any fees received, or likely to have been received, by the person in connection with the notifiable proposal (or arrangements implementing the notifiable proposal), or with the notifiable arrangements, and (b) in the case of a penalty for a person's failure to comply with section 309(1) or 310, to the amount of any advantage gained, or sought to be gained, by the person in relation to any tax prescribed under section 306(1)(b) in relation to the notifiable arrangements. (2ZC) If the maximum penalty under subsection (1)(a)(i) above appears inappropriately low after taking account of those considerations, the penalty is to be of such amount not exceeding £1 million as appears appropriate having regard to those considerations. (2ZD) Where it appears to an officer of Revenue and Customs that a penalty under subsection (1)(a)(i) above has been determined on the basis that the initial period begins with a day later than that which the officer considers to be the relevant day, an officer of Revenue and Customs may commence proceedings for a re-determination of the penalty. (2ZE) The Treasury may by regulations vary— (a) any of the sums for the time being specified in subsection (1) above, and (b) the sum specified in subsection (2ZC) above.

• (5) In subsection (2A), for “amount specified in subsection (1)(b) above shall be increased to the prescribed sum” substitute “ amounts specified in subsection (1)(a)(i) and (b) above shall be increased to the prescribed sum in relation to days falling after the prescribed period ”.

• (6) In subsection (2B), for “amount specified in subsection (1)(b)” substitute “ amounts specified in subsection (1)(a)(i) and (b) ”.

• (7) In subsection (2C)(b), after “section” insert “ 306A or ”.

• (8) In subsection (2D), after “under section” insert “ 306A or ”.

• (9) In subsection (2E), after “under section” insert “ 306A or ”.

• (10) In subsection (2F)—

• (a) in the opening words, for “subsection (2C)” substitute “ this section ”, and

• (b) in paragraph (c), after “subsection” insert “ (2ZE) or ”.

Commencement

11

• (1) The amendments made by this Schedule come into force on such day as the Treasury may by order made by statutory instrument appoint.

• (2) An order may appoint different days for different provisions or for different purposes.

SCHEDULE 18

Main changes

1

Chapter 3 of Part 9 of CTA 2010 (sale of lessors: leasing business carried on by company alone) is amended as follows.

2

• (1) Section 382 (introduction to Chapter) is amended as follows.

• (2) In subsection (1)—

• (a) for “qualifying change of ownership in relation to” substitute “ relevant change in the relationship between ”, and

• (b) insert at the end “ and a principal company of the company. ”

• (3) In subsection (3), for “ “qualifying change of ownership”, see sections 392 to 398.” substitute “relevant change in the relationship between a company and a principal company of the company”, see sections 392 to 394. ”

3

In section 383 (income and matching expense in different accounting periods), after subsection (1) insert—

(1A) For the meaning of “qualifying change of ownership”, see sections 394A to 398A

4

For section 392 (and the italic heading before it) substitute—

(392) For the purposes of the sales of lessors Chapters there is a relevant change in the relationship between a company (“A”) and a principal company of A on any day in any of the circumstances in section 393 or 394 (qualifying 75% subsidiaries and consortium relationships).

5

After section 394 insert—

(394A) For the purposes of the sales of lessors Chapters there is a qualifying change of ownership in relation to a company (“A”) on any day if there is a relevant change in the relationship on that day between A and a principal company of A unless any of the following apply— (a) section 395(2), (b) section 396(2), or (c) section 398A(2) or (5).

6

After section 398 insert—

(398A) (1) This section applies if— (a) on any day (“the relevant day”) a company (“A”) carries on a business of leasing plant or machinery otherwise than in partnership, (b) there is a relevant change in the relationship between A and a principal company of A (“P”) on the relevant day, and (c) an election that this section is to apply is made by A. (2) For the purposes of the sales of lessors Chapters, there is no qualifying change of ownership in relation to A on the relevant day as a result of the change in the relationship but— (a) subsections (2)(b) and (4)(b) of section 383 nevertheless apply, (b) section 398D (and section 398C so far as relating to it) has effect during the relevant period, and (c) sections 398E to 398G (and section 398C so far as relating to section 398E) have effect on the relevant day and during the relevant period. (3) “The relevant period” is the period— (a) beginning with the day after the relevant day, and (b) ending with the day on which there is next a relevant change in the relationship between A and a principal company of A falling within subsection (4) (or continuing indefinitely if there is not another such relevant change). (4) A relevant change in the relationship between A and a principal company of A falls within this subsection if, as a result of it, the (unadjusted) basic amount (see section 399) is (or, but for a further election, would be) treated as a receipt of the business of leasing plant or machinery carried on by A. (5) Where during the relevant period there is a relevant change in the relationship between A and a principal company of A but the relevant period is not brought to an end by it, for the purposes of the sales of lessors Chapters there is no qualifying change of ownership in relation to A as a result of the change in the relationship. (398B) (1) The election under section 398A must state the date of the relevant day. (2) The election must be made— (a) by notice to an officer of Revenue and Customs, and (b) during the period of two years beginning with the relevant day. (3) The election is irrevocable. (4) All such assessments and adjustments of assessments are to be made as are necessary to give effect to the election. (398C) (1) Sections 398D and 398E make special provision about the trade or property business consisting of or including A's business of leasing plant or machinery. (2) In those sections “the relevant activity” means— (a) if A's business of leasing plant or machinery constitutes or forms part of a trade, that trade, and (b) if it forms part of a property business, that property business. (398D) (1) No loss may be deducted under— (a) Chapter 2 of Part 4, (b) section 62, or (c) section 189, from so much of the total profits of A as are attributable to the carrying on of the relevant activity except to the extent that the loss or charge is attributable to the carrying on of the relevant activity. (2) Group relief is not to be given under Part 5 against so much of the total profits of A as are attributable to the carrying on of the relevant activity. (3) No deficit may be set off under section 461 of CTA 2009 (non-trading deficit from loan relationship) against profits attributable to the carrying on of the relevant activity except to the extent that the deficit is attributable to the carrying on of the relevant activity. (4) No loss may be set off under section 753 of CTA 2009 (non-trading loss on intangible fixed assets) against so much of the total profits of A as are attributable to the carrying on of the relevant activity except to the extent that the loss or charge is attributable to the carrying on of the relevant activity. (5) No deduction is to be allowed under section 1219 of CTA 2009 (expenses of management of investment business) from so much of the total profits of A as are attributable to the carrying on of the relevant activity except to the extent that the expenses concerned are attributable to the carrying on of the relevant activity. (6) If A is a controlled foreign company within the meaning of Chapter 4 of Part 17 of ICTA in relation to which an apportionment falls to be made under section 747(3) of that Act in respect of the accounting period ending with the relevant day, no sum may be set off under paragraph 1 of Schedule 26 to ICTA by any person in respect of so much of the chargeable profits of A as are apportioned to the person and are attributable to the carrying on of the relevant activity. (7) If A would otherwise be a tonnage tax company under Schedule 22 to FA 2000 (tonnage tax) it is to be treated as not being such a company. (398E) (1) This section applies if any expenditure incurred by A in carrying on the relevant activity has an unallowable purpose. (2) In calculating the profits or losses of A for any accounting period for the purposes of corporation tax so much of the expenditure as, on a just and reasonable apportionment, is attributable to the unallowable purpose is to be left out of account. (3) Expenditure has an unallowable purpose if the main purpose, or one of the main purposes, of A in incurring it is to obtain a relevant tax advantage (“the unallowable purpose”). (4) A “relevant tax advantage” is— (a) a reduction in the profits which, for the purposes of corporation tax, are attributable to the carrying on of the relevant activity by A, (b) the creation of a loss which, for those purposes, is so attributable, or (c) an increase in losses which, for those purposes, are so attributable. (398F) (1) Expenditure incurred by A in providing plant or machinery is not qualifying expenditure for the purposes of Part 2 of CAA 2001 if the expenditure is incurred on the acquisition or creation of an independent asset. (2) An asset is an “independent” asset if, in the normal course of business— (a) it could be used individually (whether or not it could also be used in conjunction with another asset or other assets as a constituent part of a single asset consisting of more than one asset (a “combined asset”)), or (b) it could be used (at different times) as a constituent part of different combined assets. (398G) (1) Section 948 does not apply where A is the predecessor or the successor. (2) Where section 948 does not apply as a result of subsection (1), the plant or machinery belonging to the trade is to be treated for the purposes of the Corporation Tax Acts as sold by the predecessor to the successor on the day of cessation for an amount equal to its market value on that day. (3) Where A is the predecessor, section 265(2)(b) of CAA 2001 (successions) applies— (a) even if the relevant property has been sold to the successor, and (b) as if the reference to market value were to market value as determined in accordance with section 437(9).

Interpretation

7

In section 437 of CTA 2010 (interpretation of the sales of lessors Chapters), after subsection (8) insert—

(8A) Property business” means a UK property business or an overseas property business.

8

In Schedule 4 to that Act (index of defined expressions), insert at the appropriate places—

property business (in Chapters 3 to 6 of Part 9)	section 437(8A)”
“relevant change in relationship (in Chapters 3 to 6 of Part 9)	section 392

and in the entry relating to “qualifying change of ownership in relation to a company (in Chapters 3 to 6 of Part 9)” for “392 to 398” substitute “ 394A to 398A ”).

Commencement etc

9

The amendments made by this Schedule have effect where the relevant day is on or after 9 December 2009.

10

Amendments corresponding to those made by this Schedule, having effect where the relevant day is on or after that date, are to be treated as having been made in Schedule 10 to FA 2006.

11

Neither section 398F of CTA 2010 (inserted by paragraph 6) nor the corresponding provision treated as inserted by paragraph 10 apply in relation to expenditure incurred in pursuance of a written contract which is finalised by A before 9 December 2009; and for this purpose a contract is finalised on the earliest date on which—

• (a) it is unconditional or (if conditional) the conditions are met, and

• (b) no terms remain to be agreed.

12

Section 398A of CTA 2010 (as inserted by paragraph 6) has effect in relation to a relevant change in the relationship between A and a principal company of A in the case of which the relevant day is before 24 March 2010 as if—

• (a) in subsection (3)(b), the words “falling within subsection (4)”, and

• (b) subsections (4) and (5),

were omitted.

13

Section 398D of CTA 2010 (as inserted by paragraph 6)—

• (a) has effect with the omission of subsection (6) in relation to accounting periods beginning before 24 March 2010, and

• (b) has effect with the omission of subsection (7) until that date.

SCHEDULE 19

Loan relationships

1

In Chapter 18 of Part 5 of CTA 2009 (loan relationships: general and supplementary provision), before section 466 (and the heading before it) insert—

(465A) (1) The Treasury may by regulations make provision for cases where, in consequence of a change in accounting standards, there is a relevant accounting change. (2) “Change in accounting standards” means the issue, revocation, amendment or recognition of, or withdrawal of recognition from, an accounting standard by an accounting body. (3) “Relevant accounting change” means a change in the way in which a company is permitted or required, for accounting purposes, to recognise amounts which— (a) are brought into account by the company as credits or debits for any period for the purposes of this Part, or (b) would be so brought into account but for any provision made by or under this Part. (4) Regulations under subsection (1) may amend this Part (apart from this section). (5) Regulations under subsection (1) may— (a) make different provision for different cases, (b) make incidental, supplemental, consequential and transitional provision and savings, and (c) make provision subject to an election or other specified circumstances. (6) Regulations making consequential provision by virtue of subsection (5)(b) may, in particular, include provision amending a provision of the Corporation Tax Acts. (7) Regulations under subsection (1) may apply to a pre-commencement period if they make provision in relation to a relevant accounting change which may or must be adopted, for accounting purposes, for a period of account, or part of a period of account, which coincides with that pre-commencement period. (8) In this section— - “accounting body” means the International Accounting Standards Board or the Accounting Standards Board, or a successor body to either of those Boards; - “accounting standard” includes any statement of practice, guidance or other similar document; - “pre-commencement period”, in relation to regulations, means an accounting period, or part of an accounting period, which begins before the regulations are made.

Derivative contracts

2

In Chapter 13 of Part 7 of CTA 2009 (derivative contracts: general and supplementary provision), after section 701 insert—

(701A) (1) The Treasury may by regulations make provision for cases where, in consequence of a change in accounting standards, there is a relevant accounting change. (2) “Change in accounting standards” means the issue, revocation, amendment or recognition of, or withdrawal of recognition from, an accounting standard by an accounting body. (3) “Relevant accounting change” means a change in the way in which a company is permitted or required, for accounting purposes, to recognise amounts which— (a) are brought into account by the company as credits or debits for any period for the purposes of this Part, or (b) would be so brought into account but for any provision made by or under this Part. (4) Regulations under subsection (1) may amend this Part (apart from this section). (5) Regulations under subsection (1) may— (a) make different provision for different cases, (b) make incidental, supplemental, consequential and transitional provision and savings, and (c) make provision subject to an election or other specified circumstances. (6) Regulations making consequential provision by virtue of subsection (5)(b) may, in particular, include provision amending a provision of the Corporation Tax Acts. (7) Regulations under subsection (1) may apply to a pre-commencement period if they make provision in relation to a relevant accounting change which may or must be adopted, for accounting purposes, for a period of account (or part of a period of account) which coincides with that pre-commencement period. (8) In this section— - “accounting body” means the International Accounting Standards Board or the Accounting Standards Board, or a successor body to either of those Boards; - “accounting standard” includes any statement of practice, guidance or other similar document; - “pre-commencement period”, in relation to regulations, means an accounting period (or part of an accounting period) which begins before the regulations are made.

Affirmative resolution procedure

3

In section 1310(4) of CTA 2009 (orders and regulations subject to affirmative resolution of House of Commons), before paragraph (za) insert—

(zza) section 465A or 701A (powers to make regulations where accounting standards change),

.

SCHEDULE 20

Exemption from income tax

1

• (1) This paragraph applies if an employee or contractor of an overseas team which competes in the 2011 Champions League final (“the final”) is neither UK resident nor ordinarily UK resident at the time of the final.

• (2) That person is not liable to income tax in respect of any income arising to the person which is related to duties or services performed by the person in the United Kingdom in connection with the final.

• (3) This paragraph is subject to paragraphs 2 and 3.

• (4) For the meaning of some expressions used in this paragraph, see paragraphs 5 and 6.

Exclusion of certain income

2

Paragraph 1(2) does not apply to income which arises as a result of—

• (a) a contract entered into after the final, or

• (b) any amendment, after the final, of a contract entered into before the end of the final.

Tax avoidance

3

• (1) This paragraph applies if conditions A and B are met.

• (2) Condition A is that arrangements have been made which, but for this paragraph, would result in a person obtaining exemption under paragraph 1 in respect of particular income.

• (3) Condition B is that those arrangements have, or form part of arrangements which have, as their main purpose, or one of their main purposes, the obtaining of that exemption.

• (4) Paragraph 1(2) does not apply to that income.

Disapplication of section 966 of ITA 2007

4

Section 966 of ITA 2007 (duty to deduct and account for sums representing income tax) does not apply to any payment or transfer which gives rise to income within paragraph 1(2).

Interpretation

5

References in this Schedule to income are to be read as references to—

• (a) income that would be employment income but for the provisions of paragraph 1, and

• (b) profits of a trade, profession or vocation (including profits treated as arising as a result of provision made by or under sections 13 and 14 of ITTOIA 2005).

6

In this Schedule—

• “the 2011 Champions League final” means the final of the UEFA Champions League 2010/2011 competition held in England in 2011;

• “contractor”, in relation to an overseas team, means an individual who is not an employee of the team but who performs services for the team—under the terms of a contract with the team, orunder the terms of a contract, or that individual's employment, with a company which is a member of the same group of companies as the team (within the meaning given by section 152 of CTA 2010);

• “employee” and “employment” are to be read in accordance with section 4 of ITEPA 2003;

• “overseas team” means a football club which is not a member of the Football Association, the Scottish Football Association, the Football Association of Wales or the Irish Football Association.

Charge, main rates, thresholds and allowances etc for 2010-11

Annual investment allowance

Rate in respect of residential property where consideration over £1m

Rates for motorcycles

Fuel duties: rates and rebates from April 2010

Fuel duties: further changes in rates and rebates

Rates of air passenger duty

Standard rate of landfill tax

Rates of climate change levy

Rates of climate change levy

Rates of gaming duty

Sideways relief etc

Sideways relief etc

Sale of lessors: consortium relationships

Charities and community amateur sports clubs: definitions

Transactions in securities

Transactions in securities

Unauthorised unit trusts

Risk transfer schemes

Risk transfer schemes

Information

Insurance premium tax: separate contracts

Reversionary interests of purchaser or settlor etc in relevant property

SDRT: depositary receipt systems and clearance services systems

SDLT: partnerships

Zero and low emission vehicles

Cars with CO2 emissions figure

Sale of lessors: election out of charge

Alcoholic liquor duties: power to amend definition of “cider”

Interpretation

Interpretation

The tax

Rate

“Taxable company”

“Relevant remuneration”

“Excluded remuneration”

“Awarded”

“Amount” of remuneration

“The chargeable period”

“Relevant banking employee”

Multiple employments

Payments etc to intermediaries

Arrangements for future payments etc

Loans

Anti-avoidance

No deduction in computing profits

Responsibility for collection and management

Due date for payment

Obligation to deliver return

Content etc of return

Failure to include self-assessment

Amendment of return by company

Correction of return by HMRC

Enquiry into return

Determination by HMRC

Discovery assessment by HMRC

Collection and recovery

Interest on late payments and repayments

Overpaid tax etc

Appeals and other proceedings

Obligation to preserve records

Information powers

Penalties

Miscellaneous

“UK resident bank” and “relevant foreign bank”

“Relevant regulated activity”, “capital resources condition”, “excluded company”, “asset management activities”, “linked entity” etc

“Member of a banking group”

“The trading income of the group” for the relevant period

“Investment company” etc

“Financial trading company” etc

Other interpretative provisions

Amendments of Chapter 2 of Part 4 of ITA 2007

Other amendments

Commencement

Restriction of qualifying expenditure

Restriction of deduction for rental rebate

Arrangements reducing disposal value of asset

Definition of “charity” etc

Jurisdiction condition

Registration condition

Management condition

Periods over which management condition treated as met

Publication of names and addresses of bodies or trusts regarded by HMRC as charities

Enactments to which this Part applies

FA 1982

FA 1983

IHTA 1984

FA 1986

FA 1989

TCGA 1992

F(No.2)A 1997

FA 1999

CAA 2001

ITEPA 2003

FA 2003

ITTOIA 2005

F(No.2)A 2005

ITA 2007

FA 2008

CTA 2009

FA 2009

CTA 2010

TIOPA 2010

Power to make further consequential provision

Commencement of Part 1

Commencement of Part 2

Commencement of Part 3

Gifts by individuals

Gifts by companies

Commencement and corresponding ICTA amendments

Payroll giving

Payments to bodies outside the UK: non-charitable expenditure

Gift aid: disqualified overseas gifts

Gift aid administration: charitable trusts

Gift aid administration: charitable companies

Commencement

Schedule 24 to FA 2007

Schedule 41 to FA 2008

Schedule 55 to FA 2009

Effect of foreign tax becoming payable

Schemes about deemed foreign tax

Foreign tax payable by other participants

Claims etc made before scheme or arrangement made

Limit on reduction for foreign tax

Income tax

Corporation tax

Consequential amendments

Commencement

Amendments of Chapter 13 of Part 15 of ITA 2007

Consequential amendments

Commencement

Transitional provision: opening value of trustees' double tax relief pool

Amendments of Chapter 12 of Part 5 of CTA 2009

Consequential amendment

Commencement

Transitional provision

Amendments of section 322 of CTA 2009

Amendments of Chapter 6 of Part 5 of CTA 2009

Commencement

Transitional provision

Amendments

Commencement and transitional provision

Introduction

Initial marketing

Promoters to provide client lists

Information provided to introducers

Penalties

Commencement

Main changes

Interpretation

Commencement etc

Loan relationships

Derivative contracts

Affirmative resolution procedure

Exemption from income tax

Exclusion of certain income

Tax avoidance

Disapplication of section 966 of ITA 2007

Interpretation

Editorial notes

[^c2125279]: Word in s. 2(2)(a) substituted (1.4.2011) by Finance Act 2011 (c. 11), s. 4

[^c2125283]: S. 16 repealed (retrospective to 31.3.2011) by Finance Act 2011 (c. 11), s. 24

[^c2125357]: S. 23 repealed (10.12.2010) by The Finance Act 2010, Section 23 and Schedule 2 (High Income Excess Relief Charge) (Repeal) Order 2010 (S.I. 2010/2938), arts. 1, 2

[^c2125256]: S. 35(2)(3) power partly exercised: 6.4.2011 appointed for specified provisions and purposes by {S.I. 2011/975}, art. 2 (with arts. 3-5)

[^c2125240]: S. 58(2)-(5) omitted (8.4.2010 with effect as mentioned in s. 59(5) of the amending Act) by virtue of Finance Act 2010 (c. 13), s. 59(4)(c)

[^c2125360]: Sch. 2 repealed (10.12.2010) by The Finance Act 2010, Section 23 and Schedule 2 (High Income Excess Relief Charge) (Repeal) Order 2010 (S.I. 2010/2938), arts. 1, 2

[^c2125277]: Sch. 6 para. 14 repealed (19.7.2011) by Finance Act 2011 (c. 11), s. 91, Sch. 26 para. 1(2)(b)(ii)

[^c2125258]: Sch. 10 para. 10 partly in force; Sch. 10 para. 10 not in force at Royal Assent see s. 35(2); Sch. 10 para. 10 in force for certain purposes at 6.4.2011 by S.I. 2011/975, art. 2(2) (with art. 5)

[^c2125260]: Sch. 10 para. 11 partly in force; Sch. 10 para. 11 not in force at Royal Assent see s. 35(2); Sch. 10 para. 11 in force for certain purposes at 6.4.2011 by S.I. 2011/975, art. 2(2) (with art. 5)

[^c2125261]: Sch. 10 para. 12 partly in force; Sch. 10 para. 12 not in force at Royal Assent see s. 35(2); Sch. 10 para. 12 in force for certain purposes at 6.4.2011 by S.I. 2011/975, art. 2(2) (with art. 5)

[^c2125262]: Sch. 10 para. 13 partly in force; Sch. 10 para. 13 not in force at Royal Assent see s. 35(2); Sch. 10 para. 13 in force for certain purposes at 6.4.2011 by S.I. 2011/975, art. 2(2) (with art. 5)

[^c2125263]: Sch. 10 para. 14 partly in force; Sch. 10 para. 14 not in force at Royal Assent see s. 35(2); Sch. 10 para. 14 in force for certain purposes at 6.4.2011 by S.I. 2011/975, art. 2(2) (with art. 5)

[^c2125287]: Sch. 14 para. 4(4) omitted (19.7.2011 with effect as mentioned in s. 60(4) of the amending Act) by virtue of Finance Act 2011 (c. 11), s. 60(3)

[^c2125235]: Sch. 17 para. 11 power fully exercised: 1.1.2011 appointed by {S.I. 2010/3019}, art. 2

[^key-2aa4c264a3da54619dac9fe4e82549ff]: Sch. 6 para. 8 in force at 8.3.2012 with effect as mentioned in art. 3 of the commencing S.I. by S.I. 2012/736, art. 3

[^key-21ae7f6fdde38010329b2435d6fae9d9]: Sch. 6 para. 10 in force at 8.3.2012, with effect as mentioned in art. 5 of the commencing S.I. by S.I. 2012/736, art. 5

[^key-6ab1ce29e322783a858f3dfcc91189a6]: Sch. 6 para. 11 in force at 8.3.2012, with effect as mentioned in art. 6 of the commencing S.I. by S.I. 2012/736, art. 6

[^key-63880cfce2c897d1e7e8c2976149f586]: Sch. 6 para. 12 in force at 8.3.2012, with effect as mentioned in art. 7 of the commencing S.I. by S.I. 2012/736, art. 7

[^key-5a8b18782607732fe0b05cb25889b1ce]: Sch. 6 para. 13(2) in force at 8.3.2012, with effect as mentioned in art. 8 of the commencing S.I. by S.I. 2012/736, art. 8

[^key-b5801bf918de30b6db0d2ad77c11c902]: Sch. 6 para. 13(3)(4)(5) in force at 8.3.2012, with effect as mentioned in art. 9 of the commencing S.I. by S.I. 2012/736, art. 9

[^key-e1636fa5b05aba97112cab8f5b87f429]: Sch. 6 para. 15(2) in force at 8.3.2012 with effect as mentioned in art. 10 of the commencing S.I. by S.I. 2012/736, art. 10

[^key-366f16ff4655f50e83330f7febd287a8]: Sch. 6 para. 16 in force at 8.3.2012, with effect as mentioned in art. 12 of the commencing S.I. by S.I. 2012/736, art. 12

[^key-099551799bb5c46d0b5f64c3113ed347]: Sch. 6 para. 17 in force at 8.3.2012, with effect as mentioned in art. 13 of the commencing S.I. by S.I. 2012/736, art. 13

[^key-e05c2619cae6d97674e9373f19fd9941]: Sch. 6 para. 19 in force at 8.3.2012, with effect as mentioned in art. 14 of the commencing S.I. by S.I. 2012/736, art. 14

[^key-82822aec278f13ea40a7f53f68a09033]: Sch. 6 para. 20 in force at 8.3.2012 with effect as mentioned in art. 14 of the commencing S.I. by S.I. 2012/736, art. 14

[^key-9da0611d955bee4c15a89f737cfe3a36]: Sch. 6 para. 21(2)(4)(5)(b) in force at 8.3.2012 with effect as mentioned in art. 15(1) of the commencing S.I. by S.I. 2012/736, art. 15(1)

[^key-e8fbeb71d65b9f18f4a467e982ff7706]: Sch. 6 para. 21(3)(5)(a) in force at 8.3.2012 with effect as mentioned in art. 15(2) of the commencing S.I. by S.I. 2012/736, art. 15(2)(3)

[^key-b3a5b1c63f3897ed412467d38342a02e]: Sch. 6 para. 23(2)-(5) (7) in force at 8.3.2012 with effect as mentioned in art. 17 of the commencing S.I. by S.I. 2012/736, art. 17

[^key-e4ac062ddef891fe5de0836213dc7424]: Sch. 6 para. 23(6) in force at 8.3.2012 with effect as mentioned in art. 18 of the commencing S.I. by S.I. 2012/736, art. 18

[^key-1f34957177ba9218bc96ed32f42e31c6]: Sch. 6 para. 27 in force at 8.3.2012 with effect as mentioned in art. 21 of the commencing S.I. by S.I. 2012/736, art. 21

[^key-f1461543fd51011c380ccef711f8b9cb]: Sch. 6 para. 28 in force at 8.3.2012 with effect as mentioned in art. 22 of the commencing S.I. by S.I. 2012/736, art. 22

[^key-6d8414d51bc2a6c2d6baee85ec1187b1]: Words in Sch. 6 para. 1(4) substituted (14.3.2012) by Charities Act 2011 (c. 25), s. 355, Sch. 7 para. 143(2)(a) (with s. 20(2), Sch. 8)

[^key-deba6a0a6441ed66e693bdaf0c6e1bb9]: Words in Sch. 6 para. 1(4)(b) substituted (14.3.2012) by Charities Act 2011 (c. 25), s. 355, Sch. 7 para. 143(2)(b) (with s. 20(2), Sch. 8)

[^key-d8cb75edd5b8da9ee5e62a9d22dbbfea]: Words in Sch. 6 para. 3(1)(a) substituted (14.3.2012) by Charities Act 2011 (c. 25), s. 355, Sch. 7 para. 143(3) (with s. 20(2), Sch. 8)

[^key-135a6bd5f0eb219a12c49ed34bd6abe8]: Words in Sch. 6 para. 3(2) substituted (14.3.2012) by Charities Act 2011 (c. 25), s. 355, Sch. 7 para. 143(4) (with s. 20(2), Sch. 8)

[^key-ebd3a5433aa3b7b47695b265e86cc8ae]: Sch. 6 para. 9 in force at 1.4.2012 by S.I. 2012/736, art. 4

[^key-4fb678d730656701a3f1c5f89e79b209]: Sch. 6 para. 15(3) in force at 1.4.2012 by S.I. 2012/736, art. 11

[^key-19647e3f0dd5453621eee7554a74d3af]: Sch. 6 para. 22 in force at 1.4.2012 by S.I. 2012/736, art. 16

[^key-48e3c66ae4dbd4a0f66626d9c7e57968]: Sch. 6 para. 24 in force at 1.4.2012 by S.I. 2012/736, art. 19

[^key-ad3b88a0b26f359c38bcc659cbc61c57]: Sch. 6 para. 26 in force at 1.4.2012 by S.I. 2012/736, art. 20

[^key-4955668e67b15d9c6a02e9ec074e3cb6]: Sch. 6 para. 31 omitted (retrospective to 6.4.2012) by virtue of Finance Act 2012 (c. 14), s. 52(2)(3)

[^key-370daed058dd11e501feb2091ece0b2b]: Sch. 8 para. 3(4) repealed (retrospective to 6.4.2012) by Finance Act 2012 (c. 14), s. 50(3)(b)(4)

[^key-032aee3decfb220b957de43ce16aed7c]: S. 47 omitted (17.7.2012) by virtue of Finance Act 2012 (c. 14), Sch. 16 para. 247(u)

[^key-6d4773f094f575aaddd783f4521fa1b1]: Sch. 8 para. 4(2) omitted (with effect in accordance with Sch. 15 para. 17(6) of the amending Act) by virtue of Finance Act 2012 (c. 14), Sch. 15 para. 12

[^key-3f3af69bc7c96feea1bbb2d762a71c29]: Sch. 8 para. 6 omitted (with effect in accordance with Sch. 15 para. 17(6) of the amending Act) by virtue of Finance Act 2012 (c. 14), Sch. 15 para. 16

[^key-2faaa7d4156c916d360ca2a381a8212b]: Words in s. 64(3) substituted (1.4.2013) by The Financial Services Act 2012 (Consequential Amendments) Order 2013 (S.I. 2013/636), art. 1(2), Sch. para. 14(2)

[^key-63d92d7c3429b57f55c6951079ab3092]: Words in Sch. 1 para. 44(12) substituted (1.4.2013) by The Financial Services Act 2012 (Consequential Amendments) Order 2013 (S.I. 2013/636), art. 1(2), Sch. para. 14(3)(a)

[^key-5a774582ac70712a134266db2ac9f549]: Sch. 1 para. 45(14)(a) (aa) substituted for Sch. 1 para. 45(14)(a) (1.4.2013) by Financial Services Act 2012 (c. 21), s. 122(3), Sch. 18 para. 130(a) (with Sch. 20); S.I. 2013/423, art. 3, Sch.

[^key-5274a9ac6b65ddbc5a35efd73132bebc]: Words in Sch. 1 para. 45(14)(b) substituted (1.4.2013) by Financial Services Act 2012 (c. 21), s. 122(3), Sch. 18 para. 130(b) (with Sch. 20); S.I. 2013/423, art. 3, Sch.

[^key-ee2d28481e208a5899fe76dd08d774b9]: Word in Sch. 6 para. 7 omitted (17.7.2013) by virtue of Finance Act 2013 (c. 29), Sch. 35 para. 3(a)

[^key-eb2979471fb9a0ac697d27e31bf4ba1c]: Sch. 6 para. 7(i) and word inserted (17.7.2013) by Finance Act 2013 (c. 29), Sch. 35 para. 3(b)

[^key-275860d6dc660f33847792eccf1260c3]: Sch. 6 para. 21(4) omitted (with effect in accordance with Sch. 12 para. 18(1) of the amending Act) by virtue of Finance Act 2013 (c. 29), Sch. 12 para. 17

[^key-071c59e0c0d4b0534bb7f5fda13fdaa1]: Sch. 13 omitted (6.4.2014) by virtue of The Unauthorised Unit Trusts (Tax) Regulations 2013 (S.I. 2013/2819), regs. 1(3), 41(f) (with reg. 32)

[^key-01ae7194ff30870eabcee8b7f920ab71]: S. 40 omitted (6.4.2014) by virtue of The Unauthorised Unit Trusts (Tax) Regulations 2013 (S.I. 2013/2819), regs. 1(3), 41(f) (with reg. 32)

[^key-a7efc8bdb52491e02c56e88eefcc40c0]: Sch. 6 para. 15(2) omitted (with effect in accordance with s. 114(4) of the amending Act) by virtue of Finance Act 2014 (c. 26), s. 114(3)(e)

[^key-5b1148b97a35630336898e190caff4be]: Words in Sch. 1 para. 44(9)(j) substituted (1.8.2014) by Co-operative and Community Benefit Societies Act 2014 (c. 14), s. 154, Sch. 4 para. 172 (with Sch. 5)

[^key-a8e406c009eb66ab449e8cb2d6fa6a38]: S. 7(1) omitted (with effect in accordance with s. 2(2) of the amending Act) by virtue of Stamp Duty Land Tax Act 2015 (c. 1), Sch. para. 21(b) (with s. 2(3)-(6))

[^key-065d4bd5623ab9b64e20a9cc7904bee5]: Sch. 6 Pt. 1 modified (26.3.2015) by Finance Act 2015 (c. 11), s. 123

[^key-e586d6cc4e27b661a26a2bbd85d76c20]: Word in Sch. 6 para. 7 omitted (with effect in accordance with s. 116 of the amending Act) by virtue of Finance Act 2015 (c. 11), ss. 115(2), 116(1)

[^key-2609ce1fdce8bb12d68b475d4b4ef60b]: Words in Sch. 6 para. 2(2) inserted (15.9.2016) by Finance Act 2016 (c. 24), s. 125

[^key-9ea2513d3a21e1bad7c25ef4ff973662]: Sch. 6 para. 7(j) and word inserted (with effect in accordance with s. 116 of the amending Act) by Finance Act 2015 (c. 11), s. 115(2)

[^M_F_72919bd0-5b84-4091-bb6e-7cbcd858a894]: Words in Sch. 1 para. 45(15) substituted (29.6.2017 for specified purposes, 3.7.2017 for specified purposes, 31.7.2017 for specified purposes, 3.1.2018 in so far as not already in force) by The Financial Services and Markets Act 2000 (Markets in Financial Instruments) Regulations 2017 (S.I. 2017/701), reg. 1(2)(3)(4)(6), Sch. 4 para. 13 (with reg. 7)

[^key-fd155571fabc6f27f67de7fe05483409]: S. 6 repealed (15.3.2018) by Finance Act 2018 (c. 3), s. 41(6)(e)

[^key-4dc4c0c288e1f5a10d4e0e21345c6962]: Sch. 6 para. 2(1)(b) and word omitted (with effect in accordance with s. 344(2)-(11) of the amending Act) by virtue of Finance (No. 2) Act 2023 (c. 30), s. 344(1)(a)

[^key-38cb9e6e287125712e067540d37d4fea]: Sch. 6 para. 2(3)-(5) omitted (with effect in accordance with s. 344(2)-(11) of the amending Act) by virtue of Finance (No. 2) Act 2023 (c. 30), s. 344(1)(b)

Rate of bingo duty

Sale of lessors: consortium relationships

Charities and community amateur sports clubs: definitions

Foreign currency bank accounts

Unauthorised unit trusts

Close companies: release of loans to participators etc

Information

Insurance premium tax: separate contracts

Reversionary interests of purchaser or settlor etc in relevant property

SDRT: depositary receipt systems and clearance services systems

SDLT: partnerships

Zero and low emission vehicles

Cars with CO2 emissions figure

Subsidised meals for employees: salary sacrifice etc

Small profits rates and fractions for financial year 2010

Annual investment allowance

Relief for first-time buyers

Rates of tobacco products duty

Fuel duties: rates and rebates from April 2010

Fuel duties: further changes in rates and rebates

Standard rate of landfill tax

Rate of aggregates levy

Rate of bingo duty

Rates of gaming duty

Sideways relief etc

Sale of lessors: consortium relationships

Charities and community amateur sports clubs: definitions

Foreign currency bank accounts

Transactions in securities

Close companies: release of loans to participators etc

Risk transfer schemes

Information

Insurance premium tax: separate contracts

Reversionary interests of purchaser or settlor etc in relevant property

SDRT: depositary receipt systems and clearance services systems

SDLT: partnerships

Zero and low emission vehicles

Cars with CO2 emissions figure

Subsidised meals for employees: salary sacrifice etc

Sale of lessors: election out of charge

Alcoholic liquor duties: power to amend definition of “cider”

Interpretation