Section 607C — Corporation Tax Act 2009: Avoidance of double charge

Avoidance of double charge 607C 1 This section applies if at any time a company (“ the relevant company ”) is required by section 607A to bring into account as a credit for the purposes of this Part an amount—

a which is brought into account as a credit for those purposes by another company, b which is brought into account in determining the assumed taxable total profits of another company for the purposes of Part 9A of TIOPA 2010 (controlled foreign companies), or c on which a person is charged to income tax.

2 In order to avoid a double charge to tax in respect of the amount, the relevant company may make a claim for one or more consequential adjustments to be made in respect of the amount brought into account as a credit.

3 On a claim under this section an officer of Revenue and Customs must make such of the consequential adjustments claimed (if any) as are just and reasonable.

4 Consequential adjustments may be made—

a in respect of any period, b by way of an assessment, the modification of an assessment, the amendment of a claim, or otherwise, and c despite any time limit imposed by or under any enactment.