222 Circumstances in which claim [for two-year averaging] may be made

222  Circumstances in which claim [for two-year averaging] may be made

(1)     An averaging claim may be made [under this section] in relation to two consecutive tax years in which a taxpayer is or has been carrying on the qualifying trade, profession or vocation if—

(a)     the relevant profits of one of the tax years are less than 75% of the relevant profits of the other tax year,

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