Section 356OL — Corporation Tax Act 2010: Profits attributable to period before relevant activities etc began

Profits attributable to period before relevant activities etc began 356OL 1 Subsection (2) applies if—

a subsection (1) of section 356OC applies because Condition D in section 356OB is met (land developed with purpose of realising a gain from its disposal when developed),

and b part of the profit or gain mentioned in that subsection is fairly attributable to a period before the intention to develop was formed.

2 Section 356OC(1) has effect as if the person mentioned in section 356OB(1) had not realised that part of the profit or gain.

3 Subsection (4) applies if—

a section 356OE(1) applies, and b part of the profit or gain mentioned in section 356OE(5) is fairly attributable to a period before the person mentioned in section 356OD(1) was a party to, or concerned in, the arrangement in question.

4 Section 356OE has effect as if the person had not realised that part of the profit or gain.

5 In applying this section account must be taken of the treatment under Part 3 of CTA 2009 (trading income) of a company which appropriates land as trading stock.