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Finance Act 2005
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69Consequences of a chargeable event: exit event Z
(1)This section applies where a chargeable event occurs in relation to C by virtue of section 66 and the exit event in question is exit event Z.
(2)C is to be treated for corporation tax purposes as receiving, immediately before the exit event, an amount of income from the relevant trade equal to the chargeable amount.
(3)Where TP is within the charge to corporation tax, an amount equal to the chargeable amount is to be treated for corporation tax purposes as a loss of TP’s trade brought forward under section 393 of ICTA (relief of trading losses against future trading profits) to the accounting period in which TP acquires the disposed rights.
(4)Where TP is within the charge to income tax, an amount equal to the chargeable amount is to be treated for income tax purposes as a loss of TP’s trade brought forward under section 385 of ICTA (carry-forward against subsequent profits) to the year of assessment in which TP acquires the disposed rights.
(5)But a loss brought forward under subsection (3) or (4) may only be set off against income which derives directly from the disposed rights.
(6)The “chargeable amount” is the difference between V1 and V2.
(7)Any income received in, or losses brought forward to, an accounting period by virtue of this section are in addition to any other income received in, or losses brought forward to, that period.
(8)This section is deemed to have come into force on 2nd December 2004.
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