Section 582 — Corporation Tax Act 2010: Early exit

Early exit 582 1 This section applies if—

a a group or a company ceases to be a UK REIT as a result of section 572 or 578, and b the group or company has been a UK REIT for a continuous period immediately before cessation of less than 10 years.

2 An officer of Revenue and Customs may direct—

a that a provision of this Part applies in relation to the group or company with a specified modification, or b that a provision of an enactment relating to corporation tax applies, does not apply or applies with modifications in relation to the group or company.

3 A direction under subsection (2)(a) may in particular—

a alter the time at which the group or company is to be taken to cease to be a UK REIT in accordance with section 572 or 578;

b disapply or alter the effect of section 534(1) or (2) , 535(1) or 535A .

4 A direction under subsection (2)(b) may in particular prevent all or a specified part of a loss, deficit or expense from being set off or otherwise used at all or in a specified manner.

5 In the case of a group, a direction under subsection (2) may relate to the group as a whole or to one or more members.

6 An appeal may be made—

a in the case of a group in relation to which a direction is given, by the principal company of the group, b in the case of a company in relation to which a direction is given, by the company.

7 On an appeal under subsection (6) that is notified to the tribunal, the tribunal may—

a quash the direction, b affirm the direction, or c vary the direction.