Section 18N — Corporation Tax Act 2009: Residual opening negative amount: “matching”

Residual opening negative amount: “matching” 18N 1 At the end of each relevant accounting period of the company (starting with the first) the residual opening negative amount is to be reduced (or further reduced) by the amount of any residual aggregate relevant profits amount of the company for the accounting period (but not to below nil).

2 For the purposes of this section the “residual opening negative amount”, at the beginning of the company's first relevant accounting period, is—

a the total opening negative amount of the company at that time, less b the aggregate of the streamed opening negative amounts of the company at that time.

3 For the purposes of this section the “ residual aggregate relevant profits amount ”, in relation to an accounting period, means the amount (if any) by which—

a the aggregate relevant profits amount of the company for the accounting period, exceeds b the aggregate of so much of any relevant profits amounts of the company for the accounting period as has effect to bring about a reduction under section 18M(1) for the accounting period.

4 In any relevant accounting period of the company for which there is a reduction under subsection (1), section 18A(1) does not apply in relation to the residual aggregate relevant profits amount of the company for the accounting period.

5 But in the case of the last relevant accounting period of the company for which there is a reduction under subsection (1), section 18A(1) is disapplied by subsection (4) only in relation to so much of the residual aggregate relevant profits amount of the company for the accounting period as is equal to the residual opening negative amount of the company at the beginning of the accounting period.

6 The company may, in its company tax return for that relevant accounting period, specify to which of the amounts forming part of the residual aggregate relevant profits amount of the company for the accounting period section 18A(1) is to apply by virtue of subsection (4).