Section 900F — Corporation Tax Act 2009: Special rule: section 900C or 900D case

Special rule: section 900C or 900D case 900F 1 This section applies in respect of a restricted asset of a company if it is a restricted asset by reason of section 900C or 900D.

2 The relevant Chapters of this Part have effect as if the company acquired the asset for the adjusted amount.

3 The adjusted amount is calculated as follows— Step 1 Find the amount— for which the company actually acquired the asset, or if different, for which it would (ignoring this section) be treated for the purposes of the Taxes Acts as having acquired the asset. Step 2 Deduct from the amount found at Step 1 such proportion of the notional deduction amount for the relevant other asset or each relevant other asset as is just and reasonable in the circumstances.

4 Where the deduction at Step 2 results in a negative value the adjusted amount is nil.

5 In subsection (3)— “ relevant other asset ” means an asset by reference to which the conditions in paragraphs (c) and (d) of section 900C(2) or (as the case may be) the conditions in section 900D(2) were met, and “ the notional deduction amount ”, in relation to a relevant other asset, means—

in a case where section 900E(2) would have applied had the company acquired the relevant other asset instead of the restricted asset, an amount equal to the market value of the relevant other asset at the time the restricted asset was acquired, and in a case where section 900E(3) would have applied had the company acquired the relevant other asset instead of the restricted asset, an amount equal to the market value of the relevant other asset at the time it was first acquired by a company on or after 1 July 2020, and in a case where subsection (2) of this section would have applied had the company acquired the relevant other asset instead of the restricted asset, the amount that would have been deducted at step 2 of subsection (3) of this section if the company had acquired the relevant other asset instead of the restricted asset.

6 In this section “ market value ” and “ the relevant Chapters of this Part ” have the same meaning as in section 900E.