57Banking companies: restrictions on loss relief etcU.K.
(1)Chapter 3 of Part 7A of CTA 2010 (restrictions on banking companies obtaining certain deductions) is amended as follows.
(2)In section 269CA (restriction on deductions for trading losses), in subsection (2), for “50%” substitute “ 25% ”.
(3)In section 269CB (restriction on deductions for non-trading deficits from loan relationships), in subsection (2), for “50%” substitute “ 25% ”.
(4)In section 269CC (restriction on deductions for management expenses etc), in step 1 in subsection (7), for “50%” substitute “ 25% ”.
(5)The amendments made by this section have effect for the purposes of determining the taxable total profits of companies for accounting periods beginning on or after 1 April 2016.
(6)For the purposes of subsection (5), where a company has an accounting period beginning before 1 April 2016 and ending on or after that date (“the straddling period”)—
(a)so much of the straddling period as falls before 1 April 2016, and so much of that period as falls on or after that date, are treated as separate accounting periods, and
(b)profits or losses of the company for the straddling period are apportioned to the two separate accounting periods—
(i)in accordance with section 1172 of CTA 2010 (time basis), or
(ii)if that method would produce a result that is unjust or unreasonable, on a just and reasonable basis.