Finance (No. 2) Act 2017

In section 1217RH (orchestra tax credits: amount of surrenderable loss) in subsection (3)(b) after “45” insert “ or 45B ”.

144

In section 1223 (carry forward expenses of management and other amounts), in subsection (1)(b), after sub-paragraph (i) (as inserted by paragraph 6(2)(b)) insert—

(ii) section 269ZD of CTA 2010 (restrictions on deductions from total profits) has effect for the accounting period, or (iii)

.

CTA 2010

145

CTA 2010 is amended as follows.

146

• (1) Section 1 (overview of Act) is amended as follows.

• (2) In subsection (2) (list of reliefs provided by Parts 4 to 7) after paragraph (f) insert—

(fa) group relief for carried-forward losses (see Part 5A),

• (3) After subsection (2) insert—

(2A) Part 7ZA contains provision restricting the amount of certain deductions which may be made in calculating the profits of a company on which corporation tax is chargeable.

147

• (1) Section 17 (interpretation of Chapter 4 of Part 2) is amended as follows.

• (2) In subsection (2) (meaning of “carried-back amount”)—

• (a) after paragraph (a) insert—

(aa) an amount carried back under section 45F (relief for terminal trade losses),

, and

• (b) in paragraph (c) after “459(1)(b)” insert “ or 463B(1)(b) ”.

• (3) In subsection (3) (meaning of “carried-forward amount”)—

• (a) in paragraph (a) after “forward of” insert “ pre-1 April 2017 ”,

• (b) after paragraph (a) insert—

(aa) an amount carried forward under section 45A (carry forward of post 1-April 2017 trade loss against total profits), (ab) an amount carried forward under section 45B (carry forward of post-1 April 2017 trade loss against subsequent trade profits),

, and

• (c) in paragraph (i) after “457(3)” insert “ , 463G(6) or 463H(4) ”.

148

• (1) Section 46 (use of trade-related interest and dividends if insufficient trade profits) is amended as follows.

• (2) For subsection (1) substitute—

(1) This section applies if in an accounting period a company carrying on a trade makes a loss in the trade and either— (a) relief for the loss could be given in a later accounting period under section 45(4)(b) or 45B(4) but for the fact that there are no profits of the trade of the later accounting period, or (b) the amount of relief for the loss that could be given in a later accounting period under section 45(4)(b) or 45B(4) is limited by reason of the amount of profits of the trade of the later accounting period.

• (3) In subsection (2) at the beginning insert “ For the purposes of section 45 and 45B, ”.

149

In section 47 (registered societies), in subsection (1), for “section 45” substitute “ sections 45 and 45B ”.

150

In section 53 (leasing contracts and company reconstructions), in subsection (1)(e), for “or 45” substitute “ , 45, 45A or 45B ”.

151

In section 54 (non-UK resident company: receipts of interest, dividends or royalties), in subsection (2), for “or 45” substitute “ , 45, 45A or 45B ”.

152

• (1) Section 56 (restriction on reliefs for limited partners) is amended as follows.

• (2) In subsection (2)—

• (a) in paragraph (a) after “37” insert “ or 45A ”,

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

• (c) after paragraph (b) insert

, or (c) under Part 5A (group relief for carried-forward losses)

.

• (3) In subsection (4)—

• (a) after “37” insert “ or 45A ”, and

• (b) after “5” insert “ or 5A ”.

153

• (1) Section 59 (restriction on relief for members of LLPs) is amended as follows.

• (2) In subsection (2)—

• (a) in paragraph (a) after “37” insert “ or 45A ”,

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

• (c) after paragraph (b) insert

, or (c) under Part 5A (group relief for carried-forward losses)

.

• (3) In subsection (4)—

• (a) after “37” insert “ or 45A ”, and

• (b) after “5” insert “ or 5A ”.

154

• (1) Section 61 (unrelieved losses of member of LLP brought forward) is amended as follows.

• (2) In subsection (1), in the words before paragraph (a), for “This section” substitute “ Subsection (2) ”.

• (3) After subsection (2) insert—

(2A) Subsection (2B) applies if— (a) a company (“the member company”) carries on a trade as a member of an LLP at a time during an accounting period (“the current period”), and (b) as a result of section 59, relief under section 45A or Part 5A (group relief for carried forward losses) has not been given for an amount of loss made in the trade by the member company as a member of the LLP in a previous accounting period. (2B) For the purposes of determining the relief under section 45A or Part 5A to be given to any company, the amount of loss is treated as having been made by the member company in the current period so far as it is not excluded by subsection (3) or (4).

• (4) In subsection (3)—

• (a) after “37” insert “ or 45A ”, and

• (b) after “Part 5” insert “ or Part 5A ”.

155

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

156

• (1) Section 95 (write-off of government investment: meaning of “carry forward losses”) is amended as follows.

• (2) In subsection (1), in Type 1, after “45,” insert “ 45A, 45B, ”.

• (3) In subsection (2) after “(group relief)” insert “ or Part 5A (group relief for carried forward losses) ”.

157

In section 99 (surrendering of losses and other amounts) in subsection (1)(c) after “16” insert “ or 16A ”.

158

In section 104 (meaning of “non-trading loss on intangible fixed assets” for purposes of section 99(1)(g)), for subsection (2) substitute—

(2) But it does not include a loss treated as a non-trading loss on intangible fixed assets for the surrender period as a result of section 753(3) of CTA 2009.

159

In section 137 (giving of group relief: deduction from total profits) in subsection (5) (list of deductions to be made after group relief is given)—

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

• (b) in paragraph (c) for “or 459” substitute “ , 459 or 463B ”, and

• (c) after paragraph (c) insert

, and (d) under section 188CK (giving of group relief for carried-forward losses: deductions from total profits)

.

160

In section 189(2) (relief for qualifying charitable donations) at the end insert “ and group relief for carried-forward losses ”.

161

In section 269DA (surcharge on banking companies) in subsection (2) (calculation of “surcharge profits”)—

• (a) in the formula, after “NBGR+” insert “ NBGRCF+ ”, and

• (b) after the definition of “NBGR” insert—

“NBGRCF” is the amount (if any) of non-banking group relief for carried-forward losses that is given in determining those taxable total profits (see section 269DBA);

.

162

After section 269DB insert—

(269DBA) (1) In section 269DA(2) “non-banking group relief for carried-forward losses” means group relief for carried-forward losses that relates to losses or other amounts that the surrendering company has for a surrender period in relation to which it is not a banking company. (2) In this section “surrendering company” and “surrender period” have the same meaning as in Part 5A (see section 188FD).

163

• (1) Section 269DC (surcharge on banking companies: meaning of “non-banking or pre-2016 loss relief) is amended as follows.

• (2) In subsection (3)(b)—

• (a) after “45” insert “ , 45A or 45B ”, and

• (b) omit “trade” in the second place that word occurs.

• (3) In subsection (4)(b)—

• (a) after “457” insert “ , 463G or 463H ”, and

• (b) omit “non-trading”.

• (4) Omit subsection (5).

164

In section 385 (sales of lessors: no carry back of loss against the income) in subsection (2) after “periods)” insert “ or section 45F (relief for terminal trade losses) ”.

165

In section 398D (sales of lessors: restrictions on use of losses etc) after subsection (2) insert—

(2A) Group relief for carried-forward losses is not to be given under Part 5A against so much of the total profits of A as are attributable to the carrying on of the relevant activity.

166

In section 427 (sales of lessors: no carry back of loss against the income) in subsection (2) after “periods)” insert “ or section 45F (relief for terminal trade losses) ”.

167

• (1) Chapter 5 of Part 9 (sales of lessors: anti-avoidance provisions) is amended as follows.

• (2) In section 432 (introduction to section 433)—

• (a) in subsection (1), in the words before paragraph (a), for “Section 433 applies” substitute “ Sections 433 and 433A apply ”, and

• (b) in subsection (2) after “that section” insert “ and section 433A ”.

• (3) In section 433 (restrictions on relief for expenses treated as incurred under Chapter 3 or 4)—

• (a) in subsection (3)—

• (i) in paragraph (a) after “of” insert “ pre-1 April 2017 ”,

• (ii) after that paragraph insert—

(ab) section 45B (carry forward of post-1 April 2017 trade loss against subsequent trade profits),

• (b) in subsection (5) after “profits)” insert “ or section 45A (carry forward of trade loss against total profits) ”, and

• (c) in subsection (6)—

• (i) after “set off” insert

— (a)

, and

• (ii) at the end insert

, or (b) by way of group relief for carried-forward losses in accordance with Chapter 2 of Part 5A (surrender of company's carried forward losses)

.

• (4) After section 433 insert—

(433A) (1) Any deduction made under section 45 or 45B in respect of the restricted loss amount is to be ignored for the purposes of the restriction in section 269ZB (restriction on sum of deductions from trading profits). (2) Any deduction made under section 62 or 63 in respect of the restricted loss amount is to be ignored for the purposes of the restriction in section 269ZD (restriction on sum of deductions from total profits).

168

In section 599 (real estate investment trusts: calculation of profits) after subsection (8) insert—

(9) No account is to be taken of Part 7ZA of this Act (restrictions on obtaining certain deductions in respect of carried-forward losses).

169

In section 601 (availability of group reliefs to a group UK REIT) in subsection (2)—

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

• (b) after paragraph (g) insert

, and (h) Part 5A of this Act (group relief for carried-forward losses)

.

170

In section 705E (shell companies: restriction on relief for non-trading loss on intangible fixed assets), in subsection (3)(b), for “debit of” substitute “ loss on intangible fixed assets for ”.

171

In section 705F(2) (shell companies: apportionment of amounts), in column 1 of the table—

• (a) in row 4, after “457(1)” insert “ , 463G or 463H ”,

• (b) in row 4, omit “basic rule for deficits:”,

• (c) in row 5, omit from “, but excluding” to the end, and

• (d) in row 6, omit from “and treated” to the end.

172

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

173

• (1) Section 888 (restrictions on leasing partnership losses) is amended as follows.

• (2) In subsection (3) after “37” insert “ or 45A ”.

• (3) In subsection (4)—

• (a) after “set off” insert

— (a)

, and

• (b) at the end insert

, or (b) by way of group relief for carried-forward losses in accordance with Chapter 2 of Part 5A (surrender of company's carried-forward losses etc)

.

• (4) In subsection (6) in the definition of “relevant loss relief provision”—

• (a) in paragraph (a) after “of” insert “ pre-1 April 2017 ”, and

• (b) after that paragraph insert—

(ab) section 45B (carry forward of post-1 April 2017 trade loss against subsequent trade profits),

.

174

• (1) Schedule 4 (index of defined expressions) is amended as follows.

• (2) At the appropriate places insert—

the claimant company (in Part 5A)	section 188FD
the claim period (in Part 5A)	section 188FD
---	---
company (in Part 5A)	section 188FD
---	---
“group relief for carried-forward losses”	section 188AA(4)
---	---
holding company (in Part 5A)	section 188FC(2)
---	---
member of a consortium (in Part 5A)	section 153(2) (applied by section 188FB)
---	---
member of the same group of companies (in Part 5A)	section 152 (applied by section 188FB)
---	---
owned by a consortium (in Part 5A)	section 153(1) and (3) (applied by section 188FB)
---	---
profits (in Part 5A)	section 188FD
---	---
“the specified loss-making period” (in Part 5A)	section 188FD
---	---
75% subsidiary (in Part 5A)	section 151 (applied by section 188FB)
---	---
the surrenderable amounts (in Part 5A)	section 188FD
---	---
the surrendering company (in Part 5A)	section 188FD
---	---
the surrender period (in Part 5A)	section 188FD
---	---
trade (in Part 5A)	section 188FD
---	---
trading company (in Part 5A)	section 188FC(1)
---	---

• (3) In the entry for “75% subsidiary (except in Part 5)” after “Part 5” insert “ and Part 5A ”.

TIOPA 2010

175

TIOPA 2010 is amended as follows.

176

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) ”.

177

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) ”.

178

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).

179

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 ”.

180

After section 371SK insert—

(371SKA) (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.

181

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 ”.

F (No. 3) A 2010

182

• (1) In paragraph 10 of Schedule 9 to F(No.3)A 2010 (interest), the new Part A1 to be inserted into Schedule 54 to FA 2009 is amended as follows.

• (2) In paragraph A1 (interest on tax repaid as a result of carrying back a non-trading deficit on company's loan relationships)—

• (a) in sub-paragraph (1)(c) for “or 459(1)(b)” substitute “ , 459(1)(b) or 463B(1)(b) ”, and

• (b) in sub-paragraph (2) for “or 459(1)(b)” substitute “ , 459(1)(b) or 463B(1)(b) ”.

• (3) After paragraph A2 insert—

(A2A) (1) This paragraph applies where— (a) a company has profits arising in an accounting period (“the earlier period”), (b) the company ceases to carry on a trade in a later accounting period (“the later period”), (c) on a claim under section 45F of CTA 2010 (terminal losses), the whole or any part of a loss incurred in the trade has been set off for the purposes of corporation tax against the profits of the earlier period, (d) the earlier period does not fall wholly within the period of 12 months immediately preceding the later period, and (e) a repayment falls to be made of corporation tax paid for the earlier period or of income tax in respect of a payment received by the company in that period. (2) So much of the repayment mentioned in sub-paragraph (1)(e) as falls to be made as a result of the claim under section 45F does not carry repayment interest. (3) But sub-paragraph (2) does not apply (and, accordingly, the amount mentioned in that sub-paragraph carries repayment interest) after the expiry of 9 months from the end of the later period.

• (4) In paragraph A3 (interest on tax repaid as a result of a claim under section 77 of TIOPA 2010) in sub-paragraph (4) after “A4” insert “ or A5 ”.

• (5) After paragraph A4 insert—

(A5) (1) This paragraph applies where— (a) a company has profits arising in an accounting period (“the middle period”), (b) the company ceases to carry on a trade in a later accounting period (“the later period”), (c) on a claim under section 45F of CTA 2010 (terminal losses), the whole or any part of a loss incurred in the trade has been set off for the purposes of corporation tax against the profits of the middle period, (d) the middle period does not fall wholly within the period of 12 months immediately preceding the later period, (e) as a result of the claim under section 45F, an excess or increased excess arises in the middle period as described in section 72 of TIOPA 2010 (amounts of unrelieved foreign tax), (f) on a claim under section 77 of that Act, credit for the whole or any part of the excess is allowed against corporation tax in respect of an accounting period before the middle period (“the earlier period”) and, (g) a repayment falls to be made of corporation tax paid for the earlier period or of income tax in respect of a payment received by the company in that period. (2) So much of the repayment mentioned in sub-paragraph (1)(g) as falls to be made as a result of the claim under section 77 does not carry repayment interest. (3) But sub-paragraph (2) does not apply (and, accordingly, the amount mentioned in that sub-paragraph carries repayment interest) after the expiry of 9 months from the end of the later period.

FA 2012

183

FA 2012 is amended as follows.

184

In section 78 (meaning of expressions used in section 76), in subsection (5), for the words from “means” to the end substitute

means any of the following— (a) a BLAGAB trade loss of the company for the accounting period in question, so far as relief is given for the loss under— (i) section 37 of CTA 2010 (relief for trade losses against total income), as applied by section 123, or (ii) Chapter 4 of Part 5 of that Act (group relief), as applied by section 125; (b) an amount deducted under section 124B (relief for excess carried forward post-1 April BLAGAB trade losses) from the company's total profits of the accounting period in question; (c) an amount of a BLAGAB trade loss of the company relieved under Chapter 3 of Part 5A of CTA 2010 (group relief for carried-forward losses) if the surrender period (see section 188BB(7)) to which the claim relates is the accounting period in question.

185

In section 93 (minimum profits test), in subsection (2), in the words after paragraph (b), for “and 124” substitute “ , 124, 124A and 124C ”.

186

In section 104 (meaning of “the adjusted amount”)—

• (a) in subsection (3), after “124” insert “ , 124A or 124C ”;

• (b) in subsection (4), for “that section” substitute “ any of those sections ”;

• (c) in subsection (5)(a), for “or no relief is available under that section,” substitute “ , 124A or 124C or no relief is available under those sections, ”.

187

In section 125 (group relief), at the end insert—

(4) For provision about the application of Part 5A of CTA 2010 (group relief for carried-forward losses) in relation to BLAGAB trade losses see subsections (3) to (5) of section 188BB of that Act.

188

• (1) Section 126 (restrictions in respect of non-trading deficit) is amended as follows.

• (2) After subsection (1) insert—

(1A) A loss falls within subsection (1B) so far as it— (a) would (apart from that subsection) be available for relief under section 124B (excess carried forward post-1 April 2017 losses: relief against total profits), and (b) arose in an accounting period for which the insurance company has a relevant non-trading deficit. (1B) A loss (or amount of a loss) falling within this subsection is available for relief under section 124B only so far as it exceeds the amount of that relevant non-trading deficit. (1C) A loss falls within subsection (1D) so far as it— (a) is an amount which a company (“the surrendering company“) may surrender by virtue of section 188BB(4) (surrender of carried-forward BLAGAB trade losses), and (b) arose in an accounting period for which the surrendering company has a relevant non-trading deficit. (1D) A loss (or amount of a loss) falling within this subsection is available for relief under Chapter 3 of Part 5A of CTA 2010 (claims for group relief) only so far as it exceeds the amount of that relevant non-trading deficit. (1E) For the purposes of subsections (1A) and (1C) it is to be assumed (where relevant) that in previous accounting periods losses which arose earlier have been utilised before losses which arose later.

• (3) In subsection (2)—

• (a) for “The reference” substitute “ In this section references ”;

• (b) for “is a reference” substitute “ are ”.

189

In section 127 (no relief against policyholders' share of I-E profit), in subsection (3)—

• (a) before paragraph (a) insert—

(za) relief under section 124B (relief of excess carried-forward BLAGAB trade losses against total profits),

;

• (b) after paragraph (c) insert—

(ca) relief under Chapter 3 of Part 5A of CTA 2010 (group relief for carried-forward losses),

.

PART 12 — Commencement etc

Parts 1 to 9 and 11

190

• (1) The amendments made by Parts 1 to 9 and 11 of this Schedule have effect in relation to accounting periods beginning on or after 1 April 2017.

• (2) For the purposes of those amendments, where a company has an accounting period beginning before 1 April 2017 and ending on or after that date (“the straddling period”)—

• (a) so much of the straddling period as falls before 1 April 2017, and so much of that period as falls on or after that date, are treated as separate accounting periods, and

• (b) where it is necessary to apportion an amount for the straddling period to the two separate accounting periods, it is to be apportioned—

• (i) in accordance with section 1172 of CTA 2010 (time basis), or

• (ii) if that method would produce a result that is unjust or unreasonable, on a just and reasonable basis.

• (3) But sub-paragraph (2)(b) is to be ignored if paragraph 191 or 192 applies.

191

• (1) This paragraph applies if—

• (a) an accounting period of a company (“the straddling period”) is treated as two separate accounting periods under paragraph 190(2)(a),

• (b) it is necessary to apportion an amount (“the amount concerned”) for the straddling period to the two separate accounting periods, and

• (c) the amount concerned is either—

• (i) an amount chargeable to corporation tax which would have been less but for Part 10 of TIOPA 2010 (corporate interest restriction), or

• (ii) an amount in respect of which corporation tax relief is available which would have been greater but for Part 10 of TIOPA 2010.

• (2) The amount concerned is to be apportioned as follows—

• Step 1 Determine what the amount concerned would have been but for Part 10 of TIOPA 2010 (“the notional amount”).

• Step 2 Determine what amount of the notional amount would have been apportioned to the first separate accounting period had paragraph 190(2)(b) applied (“the notional apportioned amount”). If the notional apportioned amount is less than the amount concerned, proceed with steps 3 and 4. If the notional apportioned amount is equal to or greater than the amount concerned, the whole of the amount concerned is to be apportioned to the first separate accounting period.

• Step 3 Take so much of the amount concerned as is equal to the notional apportioned amount and apportion it to the first accounting period.

• Step 4 Take the remainder of the amount concerned and apportion it to the second separate accounting period.

192

• (1) This paragraph applies if—

• (a) an accounting period of a company (“the straddling period”) is treated as two separate accounting periods under paragraph 190(2)(a),

• (b) it is necessary to apportion an amount (“the amount concerned”) for the straddling period to the two separate accounting period,

• (c) the amount concerned is an amount chargeable to corporation tax, and

• (d) the amount concerned would not have arisen but for Part 10 of TIOPA 2010 (whether or not an amount in respect of which corporation tax relief would have been available would have arisen instead).

• (2) The whole of the amount concerned is apportioned to the second separate accounting period.

Part 10

193

Section 5(4) to (6) of CT(NI)A 2015 (commencement) has effect as if references to Part 8B of CTA 2010 were to that Part as amended by Part 10 of this Schedule.

Transitional provision

194

• (1) An amount of a non-trading deficit from a company's loan relationships which is carried forward under section 463H of CTA 2009 is to be disregarded for the purposes of section 730F of CTA 2010 (as amended by paragraph 69(4)), unless it is a post-13 July 2017 amount.

• (2) An amount of a non-trading deficit from a company's loan relationships which is deducted under section 463H(5) of CTA 2009 is to be disregarded for the purposes sections 188DD and 188ED of CTA 2010, unless it is a post-13 July 2017 amount.

• (3) For the purposes of this paragraph an amount of a non-trading deficit from a company's loan relationships (“the deficit amount”) is a post-13 July 2017 amount—

• (a) if the deficit period begins on or after 13 July 2017 or,

• (b) (where the deficit period is one that begins before, and ends on or after 13 July 2017 (a “straddling deficit period”)), so far as the deficit is apportioned under sub-paragraphs (4) and (5) to the part of the deficit period that begins with 13 July 2017.

• (4) For the purposes of sub-paragraph (3)(b)—

• (a) a straddling deficit period is to be treated as consisting of two parts, namely the part that precedes, and the part that begins with, 13 July 2017,

• (b) the deficit amount is to be apportioned to those parts (see sub-paragraph (5)).

• (5) The apportionment is to be made—

• (a) in accordance with section 1172 of CTA 2010 (time basis), or

• (b) if that method would produce a result that is unjust or unreasonable, on a just and reasonable basis.

• (6) In this paragraph “deficit period” is to be interpreted in accordance with section 463A(2) of CTA 2009.

SCHEDULE 5

PART 1 — New Part 10 of TIOPA 2010

1

In TIOPA 2010, after Part 9A insert—