Corporation Tax Act 2009 section 134

Unremittable income that arose in an accounting period ending before 1 April 2009

Section 134 deals with how the rules on unremittable income relief apply to income that arose before the Corporation Tax Act 2009 came into force on 1 April 2009.

• A claim for relief on unremittable income can be made for any accounting period ending after 31 March 2009, even if the income originally arose in a period ending before 1 April 2009.
• The withdrawal of relief provisions also apply for accounting periods ending after 31 March 2009, regardless of when the income originally arose.
• It does not matter whether the original relief claim was made under the old rules (section 584 of ICTA) or the new rules (section 1275 of CTA 2009) — the withdrawal provisions apply either way.
• This ensures a seamless transition between the old and new legislation, so that pre-existing unremittable income claims are brought within the CTA 2009 framework going forward.