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(1)     CTA 2010 is amended as follows.

(2)     In section 1 (overview of Act), in subsection (3), after paragraph (ac) insert—

(3)     After Part 8B insert—

“Part 8C
Restitution Interest

Chapter 1
Amounts Taxed as Restitution Interest

357YA Charge to corporation tax on restitution interest

The charge to corporation tax on income applies to restitution interest arising to a company.

357YB Restitution interest chargeable as income

(1)     Profits arising to a company which consist of restitution interest are chargeable to tax as income under this Part (regardless of whether the profits are of an income or capital nature).

(2)     In this Part references to “profits” are to be interpreted in accordance with section 2(2) of CTA 2009.

357YC Meaning of “restitution interest”

(1)     In this Part “restitution interest” means profits in relation to which Conditions A to C are met.

(2)     Condition A is that the profits are interest paid or payable by the Commissioners in respect of a claim by the company for restitution with regard to either of the following matters (or alleged matters)—