Commentary

D4.802A Transitional rules

Corporate tax
Corporate tax | Commentary

D4.802A Transitional rules

Corporate tax | Commentary

D4.802A Transitional rules

Deferral

The new regime is deferred in circumstances where there is a total opening negative amount (essentially a loss of the PE) at the beginning of the first accounting period for which the election would otherwise have had effect1. Where there is such a loss, the relevant profits of the PE (if any) are not exempt; they are matched against the opening negative amount until the loss is extinguished2.

This rule generally applies on a global basis but provision is made for 'streaming' of such losses. Where such an election is made the transitional rule is applied separately to losses in a particular territory so that they do not delay the application of

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