Taxes Consolidation Act 1997 section 107

Apportionment of profits

Section 107 permits the apportionment, division or aggregation of profits, gains or losses where this is necessary to determine the taxable amount for a particular year of assessment or other period.

• Where profits or gains are chargeable under Case I, II or IV of Schedule D, it may be necessary to divide, apportion or aggregate those profits, gains or losses across specific periods.
• This arises where the period for which accounts have been prepared does not align with the year of assessment or other chargeable period.
• Any apportionment must be carried out on a time basis — that is, in proportion to the number of months or fractions of months in each respective period.
• The section provides the legal authority to make such apportionments, ensuring that the correct amount of profit or loss is attributed to the correct tax period.