Claims and Elections

TIOPA10/S371SF(1) requires an assumption that any beneficial claims or elections have been made that would, on the assumption of UK residence, have been available in relation to any relief under the Corporation Tax Acts to the maximum amount that would be available under that provision, and to have been made within any applicable time limit.

Where the making of a claim affects the accounting period for which relief is due, or where there is more than one possible way of claiming relief, TIOPA10/S371SF(1)(a) should be interpreted as requiring relief to be given for the maximum amount.

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