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Regulation 17 is modelled on ICTA88/S245A and follows the same approach.

Where:

• there is a change in the ownership of the company,
• an amount of unrelieved surplus ACT which was surrendered to the company, and
• within the period of six years beginning three years before the change, there is a major change in the nature or conduct of a trade or business of the company that surrendered the amount,

set off is denied for any accounting period ending after the change of ownership. »Ê¹ÚÌåÓýapp accounting period in which it occurs is treated as if the part ending with the change of ownership, and the part thereafter, were two separate accounting periods.