For periods beginning before 6 December 2010, the rule in CTA09/S599A and S599B applies where specific conditions are met (CFM56112).

Periods beginning on or after 6 December 2010

For period beginning on or after 6 December 2010, the derecognition anti-avoidance legislation operates as a general rule, wherever an amount is not fully recognised, as a result of the company being party to tax avoidance arrangements.

This change to the legislation was made by FA11/S28 and FA11/SCH4. See CFM56118 for more on commencement provisions.

The changes made with effect from that date are as follows:

Conditions A to C are repealed.

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