Part 4: Income tax, corporation tax and capital gains tax Section 37: CFC charge: tax avoidance involving carried-forward losses Details of the section
Subsection (1) explains that this section amends Part 14B of CTA 2010 (tax avoidance involving carried-over losses).
	Subsections (2), (3) and (4) introduce a definition of a relevant CFC charge advantage into carried-forward loss rules in Part 14B CTA 2010. This definition ensures that arrangements which include a deduction in a CFC fall within the scope of these anti-avoidance rules.
	Section 730G (4) of Part 14B CTA 2010 is amended to include a reference to "a relevant CFC charge advantage".
	New section 730G (5A) defines a relevant CFC charge advantage as one which involves a deductible amount.
	New section 730G (7) (aa) includes the value of any relevant CFC charge advantage in the calculation of the tax value of the arrangements which fall within the scope of Part 14B.
	Subsection (5) makes a consequential amendment.
	Subsection (6) amends section 730H (1) to include a definition of a "CFC charge advantage", which for the purposes of Part 14B, is the avoidance or reduction of a CFC charge or assessment.
	Subsection (7) provides for commencement. The changes in this section apply for accounting periods which start on or after 8 July 2015.
	Subsection (8) deals with accounting periods which start before and end after 8 July 2015. It provides for the accounting period to be split into two separate periods, so that the profits of the accounting period are be allocated between the two periods either side of the commencement date. The allocation is made on a time basis, unless a time apportionment would produce an unjust or unfair result, in which case the apportionment is on a just and reasonable basis.