[Part VIIIA Claims for Allocation of Surplus Dual Inclusion Income]

[Part VIIIA Claims for Allocation of Surplus Dual Inclusion Income]

[Introduction

77B

(1)     This Part of this Schedule applies to allocation claims under Chapter 12A of Part 6A of TIOPA 2010 (hybrid and other mismatches: allocation of dual inclusion income within group).

(2)     Expressions used in this Part of this Schedule and in that Chapter have the same meaning in this Part of this Schedule as they have in that Chapter.

Claims to be included in company tax return

77C

(1)     An allocation claim must be made by being included in the company tax return of the claimant company (“company Bâ€) for the shortfall period.

(2)     It may be included in the return originally made or by amendment.

Consent to allocation claim

77D

(1)     In accordance with Requirement 1 in section 259ZMB of TIOPA 2010, an allocation claim in respect of all or part of the DII surplus of a company (“company Aâ€) requires the company's consent.

(2)     The necessary consent must be given—

(a)     by notice in writing,

(b)     to an officer of Revenue and Customs,

(c)     at or before the time the allocation claim is made.

Otherwise the allocation claim is ineffective.

(3)

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