CTM01405 states that apportionment of accounting period profits to the relevant financial years must be made on a time basis.
It allows an (more) exact basis using transactions for accounting periods which are not of 12 months.
Does anyone have experience of HMRC allowing transaction based apportionment for a 12 month accounting period.
My client had a significantly profitable transaction in a financial year with a lower tax rate but the time apportionment meant that that profit was spread back into a prior financial year with a higher tax rate.
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Short AP?
Unless the case law of Marshall Hus & Partners v Bolton assists to allow a different basis, then only other alternative I can see is a change of accounting date.