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Version date: 3 April 2010 - onwards
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48. Amendment of section 847 (tax relief for certain branch profits) of Principal Act.

Section 847 of the Principal Act is amended -

(a) in subsection (6) by substituting "any provision of the Corporation Tax Acts other than this section" for "any other provision of the Corporation Tax Acts",

(b) in subsection (9)(b) by substituting "For the purposes of this subsection and subsection (10), where" for "Where", and

(c) by inserting the following after subsection (9):

"(10)

(a) Notwithstanding subsection (9)(a), where, in any accounting period, a qualified company incurred a loss (in this subsection referred to as a 'relevant loss') on qualified foreign trading activities and that loss formed, or formed part of, the profits or gains or losses of the company which were disregarded for the purposes of the Corporation Tax Acts by virtue of subsection (6), then the company may claim relief under section 396(1) in accordance with this subsection in respect of that loss for accounting periods beginning on or after 1 January 2011.

(b) For the purposes of a claim under paragraph (a

Comparing proposed amendment...