Section 18F — Corporation Tax Act 2009: Effect of election

Effect of election 18F 1 An election made by a company under section 18A—

a (subject to subsections (6) to (8) ) is irrevocable, and b applies to all accounting periods of the company beginning on or after the relevant day.

2 The relevant day”, in relation to an election made by a UK resident company, means—

a the day on which, at the time of the election, the company's accounting period following that in which the election is made is expected to begin, or b if the election is made before the company's first accounting period, the day on which that accounting period begins. 2A “ The relevant day ”, in relation to an election made by a non-UK resident company, means the day on which the company becomes UK resident.

3 Subsection (4) applies if an accounting period of the company (“the straddling period”) begins before, and ends on or after, the relevant day.

4 It is to be assumed, for the purposes of the Corporation Tax Acts, that the straddling period consists of two separate accounting periods—

a the first beginning with the straddling period and ending immediately before the relevant day, and b the second beginning with that day and ending with the straddling period.

5 Where for those purposes it is necessary to apportion the profits and losses for the straddling period to different parts of the period, that apportionment is to be made on a just and reasonable basis.

6 An election can be revoked by the company which made it at any time before the relevant day.

7 An election made by a UK resident company is revoked if the company ceases to be UK resident.

8 An election made by a non-UK resident company is revoked if, having become UK resident, the company ceases to be UK resident.