Part 4: Income tax, corporation tax and capital gains tax Section 36: CFC charge: abolition of relief Details of the section
Subsection (1) removes section 371UD, Part 9A, TIOPA 2010, which provides the mechanism for UK losses and expenses to be set against a CFC charge.
	Subsection (2) makes a number of consequential amendments to remove references to the CFC loss relief provisions.
	Subsection (3) provides for commencement. The change applies for CFC accounting periods which start on or after 8 July 2015.
	Subsections (4) and (5) deal with CFC accounting periods which start before and finish after 8 July 2015. It provides for a CFC accounting period to be split into two separate periods, so that the CFC profits can be allocated between the two periods either side of the commencement date. The allocation is made on a just and reasonable basis so that, for example, profits which arise after the commencement date are allocated entirely to the later period.
	Subsection (6) defines the terms used in this section.