(1) Section 865 of the Principal Act is amended by inserting the following subsection after subsection (9):

"(10)

(a) In this subsection -

‘successor company’ has the meaning assigned to it by section 638A(1);

‘transferor company’ has the meaning assigned to it by section 638A(1).

(b) Where a transferor company is a person to whom subsection (2) applies, this section shall apply as if any thing done pursuant to it or required to be done pursuant to it by or for such a person or a chargeable person, as the case may be, were, as appropriate -

(i) a thing done pursuant to it, or

(ii) a thing required to be done pursuant to it,

by or for a successor company.

(c) Where there is more than one successor company, any repayment of tax to be made under this section shall, as necessary, be apportioned on a just and reasonable basis.

(d) The amount of any repayment of tax or part repayment of tax to be made to a successor company or successor companies shall not exceed the total amount that would have been made to a transferor company but for the application of this subsection.".

(2) Subsection (1) is deemed to have come into operation on 1 June 2015.