Commentary on Sections Changes in partnership Section 1268: Election for spreading under Chapter 14 of Part 3
3234.This section sets out two rules for firms that make an election under section 186. It is based on section 114 of ICTA and paragraphs 9 and 13 of Schedule 22 to FA 2002. The corresponding rules for income tax are in section 860 of ITTOIA.
3235.Subsection (1) ensures that the adjustment charge is not “rolled up” under section 186 just because a company leaves or joins the firm.
3236.Subsection (2) is the rule about making an election under section 186. The “date on which the new basis was adopted” is defined in section 1269.