Section 952 — Corporation Tax Act 2010: Apportionment if part of trade treated as separate trade

Apportionment if part of trade treated as separate trade 952 1 If part of a trade is treated as a separate trade in accordance with section 951(2) , (4) or (8) , just and reasonable apportionments are to be made of receipts, expenses, assets and liabilities.

2 Subsection (3) applies if—

a at the time of an apportionment under subsection (1) it appears that the apportionment is material to the liability to tax (for whatever period) of two or more companies, and b a question arises as to how the apportionment is to be made for the purposes of the liability of those companies.

3 The question is to be determined in the same way as an appeal, and all the companies concerned are entitled to be a party to the proceedings.