Income Tax Act 2007 Schedule 2 paragraph 10

Changes in the law

Schedule 2 paragraph 10 provides a protective election allowing taxpayers to preserve the original tax consequences of pre-commencement events where the Income Tax Act 2007 would otherwise inadvertently alter those consequences for straddling periods.

• Where something happened before 6 April 2007 and the Act changes its tax consequences for a period straddling that date, the taxpayer may elect to be taxed as if the law had not changed
• The relevant period is any period of account (for income tax) or accounting period (for corporation tax) that began before and ended on or after 6 April 2007
• Where two or more persons are affected by the same event, all must make a corresponding election or none takes effect
• Elections must be made by the first anniversary of the normal self-assessment filing date (income tax) or within two years of the end of the accounting period (corporation tax)