Paragraph 6
(1)
The amendments made by this Schedule have effect in relation to schemes entered into at any time (including any time before the commencement date).
(2)
But section 938O in Part 21BA of CTA 2010 (as inserted by paragraph 3 of this Schedule) does not apply to—
(a)
scheme losses or profits that relate to a time before the commencement date, or
(b)
scheme profits that relate to a time on or after that date but are made in relation to a scheme entered into before that date.
(3)
In this paragraph “the commencement date” means 5 December 2012.