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Corporation Tax Act 2009

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  1. Introductory Text

  2. Part 1 Introduction

    1. A1.Overview of the Corporation Tax Acts

    2. 1.Overview of Act

  3. Part 2 Charge to corporation tax: basic provisions

    1. Chapter 1 The charge to corporation tax

      1. Charge to tax on profits

        1. 2.Charge to corporation tax

        2. 3.Exclusion of charge to income tax

        3. 4.Exclusion of charge to capital gains tax

      2. General scheme of corporation tax

        1. 5.Territorial scope of charge

        2. 6.Profits accruing in fiduciary or representative capacity

        3. 7.Profits accruing under trusts

        4. 8.How tax is charged and assessed

    2. Chapter 2 Accounting periods

      1. 9.Beginning of accounting period

      2. 10.End of accounting period

      3. 11.Companies with more than one accounting date

      4. 12.Companies being wound up

    3. Chapter 3 Company residence

      1. 13.Overview of Chapter

      2. 14.Companies incorporated in the United Kingdom

      3. 15.Continuation of residence established under common law

      4. 16.SEs which transfer registered office to the United Kingdom

      5. 17.SCEs which transfer registered office to the United Kingdom

      6. 18.Companies treated as non-UK resident under double taxation arrangements

    4. Chapter 4 Non-UK resident companies: chargeable profits

      1. Chargeable profits

        1. 19.Chargeable profits

        2. 20.Profits attributable to permanent establishment: introduction

      2. The separate enterprise principle

        1. 21.The separate enterprise principle

        2. 22.Transactions treated as being on arm's length terms

        3. 23.Provision of goods or services for permanent establishment

        4. 24.Application to insurance companies

      3. The separate enterprise principle: application to non-UK resident banks

        1. 25.Non-UK resident banks: introduction

        2. 26.Transfer of financial assets

        3. 27.Loans: attribution of financial assets and profits arising

        4. 28.Borrowing: permanent establishment acting as agent or intermediary

      4. Rules about deductions

        1. 29.Allowable deductions

        2. 30.Restriction on deductions: costs

        3. 31.Restriction on deductions: payments in respect of intangible assets

        4. 32.Restriction on deductions: interest or other financing costs

    5. Chapter 5 Supplementary

      1. 33.Trade includes office

  4. Part 3 Trading income

    1. Chapter 1 Introduction

      1. 34.Overview of Part

    2. Chapter 2 Income taxed as trade profits

      1. Charge to tax on trade profits

        1. 35.Charge to tax on trade profits

      2. Trades and trade profits

        1. 36.Farming and market gardening

        2. 37.Commercial occupation of woodlands

        3. 38.Commercial occupation of land other than woodlands

        4. 39.Profits of mines, quarries and other concerns

        5. 40.Credit unions

      3. Starting and ceasing to trade

        1. 41.Effect of company starting or ceasing to be within charge to corporation tax

      4. Trading income and property income

        1. 42.Tied premises

        2. 43.Caravan sites where trade carried on

        3. 44.Surplus business accommodation

        4. 45.Payments for wayleaves

    3. Chapter 3 Trade profits: basic rules

      1. 46.Generally accepted accounting practice

      2. 47.Losses calculated on same basis as profits

      3. 48.Receipts and expenses

      4. 49.Items treated as receipts and expenses

      5. 50.Animals kept for trade purposes

      6. 51.Relationship between rules prohibiting and allowing deductions

      7. 52.Apportionment etc of profits and losses to accounting period

    4. Chapter 4 Trade profits: rules restricting deductions

      1. 53.Capital expenditure

      2. 54.Expenses not wholly and exclusively for trade and unconnected losses

      3. 55.Bad debts

      4. 56.Car ... hire

      5. 57.Car ... hire: supplementary

      6. 58.Hiring cars (but not motor cycles) with low CO2 emissions before 1 April 2013

      7. 58A.Short-term hiring in and long-term hiring out

      8. 58B.Connected persons: application of section 56

      9. 59.Patent royalties

      10. 60.Expenditure on integral features

    5. Chapter 5 Trade profits: rules allowing deductions

      1. Pre-trading expenses

        1. 61.Pre-trading expenses

      2. Tenants under taxed leases

        1. 62.Tenants under taxed leases: introduction

        2. 63.Tenants occupying land for purposes of trade treated as incurring expenses

        3. 64.Limit on deductions if tenant entitled to mineral extraction allowance

        4. 65.Tenants dealing with land as property employed for purposes of trade

        5. 66.Restrictions on section 63 expenses: lease premium receipts

        6. 67.Restrictions on section 63 expenses: lease of part of premises

      3. Renewals

        1. 68.Replacement and alteration of trade tools

      4. Payments for restrictive undertakings

        1. 69.Payments for restrictive undertakings

      5. Seconded employees

        1. 70.Employees seconded to charities and educational establishments

        2. 71.Educational establishments

      6. Contributions to agents' expenses

        1. 72.Payroll deduction schemes: contributions to agents' expenses

      7. Counselling and retraining expenses

        1. 73.Counselling and other outplacement services

        2. 74.Retraining courses

        3. 75.Retraining courses: recovery of tax

      8. Redundancy payments etc

        1. 76.Redundancy payments and approved contractual payments

        2. 77.Payments in respect of employment wholly in employer's trade

        3. 78.Payments in respect of employment in more than one capacity

        4. 79.Additional payments

        5. 80.Application of section 79 in cases involving partnerships

        6. 81.Payments made by the Government

      9. Contributions to local enterprise organisations or urban regeneration companies

        1. 82.Contributions to local enterprise organisations or urban regeneration companies

        2. 83.Meaning of “local enterprise organisation”

        3. 84.Approval of local enterprise agencies

        4. 85.Supplementary provisions with respect to approvals

        5. 86.Meaning of “urban regeneration company”

      10. Scientific research

        1. 87.Expenses of research and development

        2. 88.Payments to research associations, universities etc

      11. Expenses connected with patents, designs and trade marks

        1. 89.Expenses connected with patents

        2. 90.Expenses connected with designs or trade marks

      12. Export Credits Guarantee Department

        1. 91.Payments to Export Credits Guarantee Department

      13. Levies under FISMA 2000

        1. 92.Levies etc under FISMA 2000

    6. Chapter 6 Trade profits: receipts

      1. Capital receipts

        1. 93.Capital receipts

      2. Debts released

        1. 94.Debts incurred and later released

      3. Amounts received following earlier cessation

        1. 95.Acquisition of trade: receipts from transferor's trade

      4. Reverse premiums

        1. 96.Reverse premiums

        2. 97.Excluded cases

        3. 98.Tax treatment of reverse premiums

        4. 99.Arrangements not at arm's length

        5. 100.Connected persons and property arrangements

      5. Other receipts

        1. 101.Distribution of assets of mutual concerns

        2. 102.Industrial development grants

        3. 103.Sums recovered under insurance policies etc

        4. 104.Repayments under FISMA 2000

    7. Chapter 7 Trade profits: gifts to charities etc

      1. Relief for certain gifts

        1. 105.Gifts of trading stock to charities etc

        2. 106.Meaning of “designated educational establishment”

        3. 107.Gifts of medical supplies and equipment

      2. Benefits associated with gifts

        1. 108.Receipt of benefits by donor or connected person

    8. Chapter 8 Trade profits: herd basis rules

      1. Introduction

        1. 109.Election for application of herd basis rules

        2. 110.Meaning of “animal”, “herd”, “production herd” etc

        3. 111.Other interpretative provisions

      2. The herd basis rules

        1. 112.Initial cost of herd and value of herd

        2. 113.Addition of animals to herd

        3. 114.Replacement of animals in herd

        4. 115.Amount of receipt if old animal slaughtered under disease control order

        5. 116.Sale of animals from herd

        6. 117.Sale of whole or substantial part of herd

        7. 118.Acquisition of new herd begun within 5 years of sale

        8. 119.Section 118: sale for reasons outside farmer's control

        9. 120.Replacement of part sold begun within 5 years of sale

        10. 121.Section 120: sale for reasons outside farmer's control

      3. Elections

        1. 122.Herd basis elections

        2. 123.Five year gap in which no production herd kept

        3. 124.Slaughter under disease control order

      4. Preventing abuse of the herd basis rules

        1. 125.Preventing abuse of the herd basis rules

      5. Supplementary

        1. 126.Information if election made

        2. 127.Further assessment etc if herd basis rules apply

    9. Chapter 9 Trade profits: other specific trades

      1. Dealers in securities etc

        1. 128.Taxation of amounts taken to reserves

        2. 129.Conversion etc of securities held as circulating capital

      2. Insurers

        1. 130. Insurers receiving distributions etc

      3. Building societies

        1. 131.Incidental costs of issuing qualifying shares

      4. Industrial and provident societies

        1. 132.Dividends etc granted by industrial and provident societies

      5. Credit unions

        1. 133.Annual payments paid by a credit union

      6. Dealers in land etc

        1. 134.Purchase or sale of woodlands

        2. 135.Relief in respect of mineral royalties

        3. 136.Lease premiums etc: reduction of receipts

      7. Mineral exploration and access

        1. 137.Mineral exploration and access

      8. Companies liable to pool betting duty

        1. 138.Payments by companies liable to pool betting duty

      9. Intermediaries treated as making employment payments

        1. 139.Deduction for deemed employment payment

        2. 140.Special rules for partnerships

      10. Managed service companies

        1. 141.Deduction for deemed employment payments

      11. Waste disposal

        1. 142.Deduction for site preparation expenditure

        2. 143.Allocation of site preparation expenditure

        3. 144.Site preparation expenditure: supplementary

        4. 145.Site restoration payments

      12. Cemeteries and crematoria

        1. 146.Cemeteries and crematoria: introduction

        2. 147.Deduction for capital expenditure

        3. 148.Allocation of ancillary capital expenditure

        4. 149.Exclusion of expenditure met by subsidies

      13. Sound recordings

        1. 150.Revenue nature of expenditure

        2. 151.Allocation of expenditure

        3. 152.Interpretation of sections 150 and 151

      14. Reserves of marketing authorities etc

        1. 153.Reserves of marketing authorities and certain other statutory bodies

        2. 154.Conditions to be met by reserve fund

        3. 155.Interpretation of sections 153 and 154

    10. Chapter 10 Trade profits: changes in trading stock

      1. Introduction

        1. 156.Meaning of “trading stock”

      2. Transfers of trading stock between trade and trader

        1. 157.Trading stock appropriated by trader

        2. 158.Trading stock supplied by trader

      3. Other disposals and acquisitions not made in the course of trade

        1. 159.Disposals not made in the course of trade

        2. 160.Acquisitions not made in the course of trade

      4. Relationship with transfer pricing rules

        1. 161.Transfer pricing rules to take precedence

    11. Chapter 11 Trade profits: valuation of stock on cessation of trade

      1. 162.Valuation of trading stock on cessation

      2. 163.Meaning of “trading stock”

      3. 164.Basis of valuation of trading stock

      4. 165.Sale basis of valuation: sale to unconnected person

      5. 166.Sale basis of valuation: sale to connected person

      6. 167.Sale basis of valuation: election by connected persons

      7. 168.Connected persons

      8. 169.Cost to buyer of stock valued on sale basis of valuation

      9. 170.Meaning of “sale” and related expressions

      10. 171.Determination of questions

    12. Chapter 12 Deductions from profits: unremittable amounts

      1. 172.Application of Chapter

      2. 173.Relief for unremittable amounts

      3. 174.Restrictions on relief

      4. 175.Withdrawal of relief

    13. Chapter 13 Disposal and acquisition of know-how

      1. 176.Meaning of “know-how” etc

      2. 177.Disposal of know-how if trade continues to be carried on

      3. 178.Disposal of know-how as part of disposal of all or part of a trade

      4. 179.Seller controlled by buyer etc

    14. Chapter 14 Adjustment on change of basis

      1. Adjustment on change of basis

        1. 180.Application of Chapter

        2. 181.Giving effect to positive and negative adjustments

        3. 182.Calculation of the adjustment

      2. Expenses previously brought into account

        1. 183.No adjustment for certain expenses previously brought into account

      3. Realising or writing off assets

        1. 184.Cases where adjustment not required until assets realised or written off

      4. Mark to market

        1. 185.Change from realisation basis to mark to market

        2. 186.Election for spreading if section 185 applies

        3. 187.Transfer of insurance business

    15. Chapter 15 Post-cessation receipts

      1. Charge to tax on post-cessation receipts

        1. 188.Charge to tax on post-cessation receipts

        2. 189.Extent of charge to tax

      2. Meaning of “post-cessation receipts”

        1. 190.Basic meaning of “post-cessation receipt”

        2. 191.Other rules about what counts as post-cessation receipts

      3. Sums treated as post-cessation receipts

        1. 192.Debts paid after cessation

        2. 193.Debts released after cessation

        3. 194.Transfer of rights if transferee does not carry on trade

      4. Sums that are not post-cessation receipts

        1. 195.Transfer of trading stock

      5. Deductions

        1. 196.Allowable deductions

        2. 197.Further rules about allowable deductions

      6. Election to carry back

        1. 198.Election to carry back

        2. 199.Deductions already made are not displaced

        3. 200.Election given effect in accounting period in which receipt is received

    16. Chapter 16 Priority rules

      1. 201.Provisions which must be given priority over this Part

  5. Part 4 Property income

    1. Chapter 1 Introduction

      1. 202.Overview of Part

    2. Chapter 2 Property businesses

      1. Introduction

        1. 203.Overview of Chapter

        2. 204.Meaning of “property business”

      2. Basic meaning of UK and overseas property business

        1. 205.UK property business

        2. 206.Overseas property business

      3. Generating income from land

        1. 207.Meaning of “generating income from land”

        2. 208.Activities not for generating income from land

    3. Chapter 3 Profits of property businesses: basic rules

      1. Charge to tax on profits of a property business

        1. 209.Charge to tax on profits of a property business

      2. Calculation of profits

        1. 210.Profits of a property business: application of trading income rules

        2. 211.Loan relationships and derivative contracts

        3. 212.Items treated as receipts and expenses

        4. 213.Certain amounts brought into account under Part 3

        5. 214.Relationship between rules prohibiting and allowing deductions

    4. Chapter 4 Profits of property businesses: lease premiums etc

      1. Introduction

        1. 215.Overview of Chapter

        2. 216.Meaning of “short-term lease”

      2. Amounts treated as receipts: leases

        1. 217.Lease premiums

        2. 218.Amount treated as lease premium where work required

        3. 219.Sums payable instead of rent

        4. 220.Sums payable for surrender of lease

        5. 221.Sums payable for variation or waiver of terms of lease

        6. 221A.Sums to which sections 217 to 221 do not apply

        7. 222.Assignments for profit of lease granted at undervalue

        8. 223.Provisions supplementary to section 222

      3. Other amounts treated as receipts

        1. 224.Sales with right to reconveyance

        2. 225.Sale and leaseback transactions

        3. 226.Provisions supplementary to sections 224 and 225

      4. Additional calculation rule for reducing certain receipts

        1. 227.Circumstances in which additional calculation rule applies

        2. 228.The additional calculation rule

        3. 229.The additional calculation rule: special cases

        4. 230.Meaning of “unused amount” and “unreduced amount”

      5. Deductions in relation to certain receipts

        1. 231.Deductions for expenses under section 232

        2. 232.Tenants under taxed leases treated as incurring expenses

        3. 233.Restrictions on section 232 expenses: the additional calculation rule

        4. 234.Restrictions on section 232 expenses: lease of part of premises

      6. Limit on effect of additional calculation rule and deductions

        1. 235.Limit on reductions and deductions

      7. Certain administrative provisions

        1. 236.Payment of tax by instalments

        2. 237.Statement of accuracy for purposes of section 222

        3. 238.Claim for repayment of tax payable by virtue of section 224

        4. 239.Claim for repayment of tax payable by virtue of section 225

      8. Determinations affecting liability of more than one person

        1. 240.Appeals against proposed determinations

        2. 241.Section 240: supplementary

        3. 242.Determination by tribunal

      9. Effective duration of lease

        1. 243.Rules for determining effective duration of lease

        2. 244.Applying the rules in section 243

        3. 245.Information about effective duration of lease

      10. Other interpretative provisions

        1. 246.Provisions about premiums

        2. 247.Interpretation

    5. Chapter 5 Profits of property businesses: other rules about receipts and deductions

      1. Furnished accommodation: receipts and deductions

        1. 248.Furnished lettings

      2. Treatment of receipts on acquisition of business

        1. 249.Acquisition of business: receipts from transferor's UK property business

      3. Reverse premiums as receipts

        1. 250.Reverse premiums

      4. Deductions for expenditure on energy-saving items

        1. 251.Deduction for expenditure on energy-saving items

        2. 252.Restrictions on relief

        3. 253.Regulations

      5. Deductions for expenditure on sea walls

        1. 254.Deduction for expenditure on sea walls

        2. 255.Transfer of interest in premises

        3. 256.Ending of lease of premises

        4. 257.Transfer involving person within the charge to income tax

      6. Mineral royalties

        1. 258.Relief in respect of mineral royalties

      7. Apportionments on sale of land

        1. 259.Nature of item apportioned on sale of estate or interest in land

      8. Mutual business

        1. 260.Mutual business

      9. Adjustment on change of basis

        1. 261.Adjustment on change of basis

        2. 262.Giving effect to positive and negative adjustments

      10. Integral features

        1. 263.Expenditure on integral features

    6. Chapter 6 Commercial letting of furnished holiday accommodation

      1. Introduction

        1. 264.Overview of Chapter

      2. Definition

        1. 265.Meaning of “commercial letting of furnished holiday accommodation”

        2. 266.Meaning of “relevant period” in sections 267 and 268

        3. 267.Meaning of “qualifying holiday accommodation”

        4. 268.Under-used holiday accommodation: averaging elections

      3. Separate profit calculations

        1. 269.Capital allowances and loss relief

    7. Chapter 7 Rent receivable in connection with a UK section 39(4) concern

      1. Charge to tax on rent receivable in connection with a UK section 39(4) concern

        1. 270.Charge to tax on rent receivable in connection with a UK section 39(4) concern

        2. 271.Meaning of “rent receivable in connection with a UK section 39(4) concern”

      2. Management expenses of owner of mineral rights

        1. 272.Deduction for management expenses of owner of mineral rights

      3. Mineral royalties

        1. 273.Relief in respect of mineral royalties

        2. 274.Meaning of “mineral lease or agreement” and “mineral royalties”

        3. 275.Extended meaning of “mineral royalties” etc in Northern Ireland

        4. 276.Power to determine what counts as “mineral royalties”

    8. Chapter 8 Rent receivable for UK electric-line wayleaves

      1. Charge to tax on rent receivable for UK electric-line wayleaves

        1. 277.Charge to tax on rent receivable for a UK electric-line wayleave

        2. 278.Meaning of “rent receivable for a UK electric-line wayleave”

        3. 279.Extent of charge to tax

    9. Chapter 9 Post-cessation receipts

      1. Charge to tax on post-cessation receipts

        1. 280.Charge to tax on post-cessation receipts

        2. 281.Extent of charge to tax

      2. Meaning of “post-cessation receipts”

        1. 282.Basic meaning of “post-cessation receipt”

        2. 283.Other rules about what counts as a “post-cessation receipt”

        3. 284.Transfer of rights if transferee does not carry on UK property business

      3. Deductions

        1. 285.Allowable deductions

      4. Election to carry back

        1. 286.Election to carry back

    10. Chapter 10 Supplementary

      1. Priority rules

        1. 287.Provisions which must be given priority over this Part

        2. 288.Priority between Chapters within this Part

      2. Other supplementary provisions

        1. 289.Effect of company starting or ceasing to be within charge to corporation tax

        2. 290.Overseas property businesses and overseas land: adaptation of rules

        3. 291.Meaning of “lease” and “premises”

  6. Part 5 Loan Relationships

    1. Chapter 1 Introduction

      1. Introduction

        1. 292.Overview of Part

        2. 293.Construction of references to profits or losses from loan relationships

        3. 294.Matters treated as loan relationships

      2. How profits and deficits from loan relationships are dealt with

        1. 295.General rule: profits arising from loan relationships chargeable as income

        2. 296.Profits and deficits to be calculated using credits and debits given by this Part

        3. 297.Trading credits and debits to be brought into account under Part 3

        4. 298.Meaning of trade and purposes of trade

        5. 299.Charge to tax on non-trading profits

        6. 300.Method of bringing non-trading deficits into account

        7. 301.Calculation of non-trading profits and deficits from loan relationships: non-trading credits and debits

    2. Chapter 2 Basic definitions

      1. 302.“Loan relationship”, “creditor relationship”, “debtor relationship”

      2. 303.“Money debt”

      3. 304.“Related transaction”

      4. 305.Payments, interest, rights and liabilities under a loan relationship

    3. Chapter 3 The credits and debits to be brought into account: general

      1. Introduction

        1. 306.Overview of Chapter

      2. General principles about the bringing into account of credits and debits

        1. 307.General principles about the bringing into account of credits and debits

      3. Amounts recognised in determining a company's profit or loss

        1. 308.Amounts recognised in determining a company's profit or loss

        2. 309.Companies without GAAP-compliant accounts

        3. 310.Power to make regulations about recognised amounts

        4. 311.Amounts not fully recognised for accounting purposes: introduction

        5. 312.Determination of credits and debits where amounts not fully recognised

      4. Accounting bases

        1. 313.Basis of accounting: “amortised cost basis”, “fair value accounting” and “fair value”

        2. 314.Power to make regulations about changes from amortised cost basis

      5. Adjustments on change of accounting policy

        1. 315.Introduction to sections 316 to 319

        2. 316.Change of accounting policy involving change of value

        3. 317.Carrying value

        4. 318.Change of accounting policy following cessation of loan relationship

        5. 319.General power to make regulations about changes in accounting policy

      6. Rules differing from generally accepted accounting practice

        1. 320.Credits and debits treated as relating to capital expenditure

        2. 321.Credits and debits recognised in equity

        3. 322.Release of debts: cases where credits not required to be brought into account

        4. 323.Meaning of expressions relating to insolvency etc

        5. 324.Restriction on debits resulting from revaluation

        6. 325.Restriction on credits resulting from reversal of disallowed debits

        7. 326.Writing off government investments

        8. 327.Disallowance of imported losses etc

      7. Exchange gains and losses

        1. 328.Exchange gains and losses

        2. 328A.Arrangements that have a “one-way exchange effect”

        3. 328B.Meaning of “relevant exchange gain” and “relevant exchange loss”

        4. 328C.Meaning of “test day”

        5. 328D.Counterfactual currency movement assumptions

        6. 328E.Counterfactual currency movement assumptions: treatment of options

        7. 328F.Meaning of “option”

        8. 328G.Meaning of “relevant contingent contract” and “operative condition”

        9. 328H.Other interpretative provisions

      8. Pre-loan relationship, abortive and pre-trading expenses

        1. 329.Pre-loan relationship and abortive expenses

        2. 330.Debits in respect of pre-trading expenditure

      9. Company ceasing to be party to loan relationship

        1. 331.Company ceasing to be party to loan relationship

        2. 332.Repo, stock lending and other transactions

      10. Company moving abroad

        1. 333.Company ceasing to be UK resident

        2. 334.Non-UK resident company ceasing to hold loan relationship for UK permanent establishment

    4. Chapter 4 Continuity of treatment on transfers within groups or on reorganisations

      1. Application of this Chapter

        1. 335.Introduction to Chapter

        2. 336.Transfers of loans on group transactions

        3. 337.Transfers of loans on insurance business transfers

        4. 338.Meaning of company replacing another as party to loan relationship

        5. 339.Issues of new securities on certain cross-border reorganisations

      2. Continuity of treatment: transfer of loan at notional carrying value

        1. 340.Group transfers and transfers of insurance business: transfer at notional carrying value

        2. 341.Transferor using fair value accounting

        3. 342.Issues of new securities on reorganisations: disposal at notional carrying value

        4. 343.Receiving company using fair value accounting

      3. Transferee leaving group after replacing transferor as party to loan relationship

        1. 344.Introduction

        2. 345.Transferee leaving group otherwise than because of exempt distribution

        3. 346.Transferee leaving group because of exempt distribution

      4. Disapplication of Chapter where transferor party to avoidance

        1. 347.Disapplication of Chapter where transferor party to avoidance

    5. Chapter 5 Connected companies relationships: introduction and general

      1. 348.Introduction: meaning of “connected companies relationship”

      2. 349.Application of amortised cost basis to connected companies relationships

      3. 350.Companies beginning to be connected

      4. 351.Companies ceasing to be connected

      5. 352.Disregard of related transactions

    6. Chapter 6 Connected companies relationships: impairment losses and releases of debts

      1. Introduction

        1. 353.Introduction to Chapter

      2. Exclusion of debits for impaired or released connected companies debts

        1. 354.Exclusion of debits for impaired or released connected companies debts

        2. 355.Cessation of connection

        3. 356.Exception to section 354: swapping debt for equity

        4. 357.Exception to section 354: insolvent creditors

      3. Exclusion of credits for connected companies debts on release or reversal of impairments

        1. 358.Exclusion of credits on release of connected companies debts: general

        2. 359.Exclusion of credits on release of connected companies debts during creditor's insolvency

        3. 360.Exclusion of credits on reversal of impairments of connected companies debts

      4. Deemed debt releases on impaired debts becoming held by connected company

        1. 361.Acquisition of creditor rights by connected company at undervalue

        2. 362.Parties becoming connected where creditor's rights subject to impairment adjustment

        3. 363.Companies connected for sections 361 and 362

    7. Chapter 7 Group relief claims involving impaired or released consortium debts

      1. 364.Introduction to Chapter

      2. 365.Reduction of impairment loss debits where group relief claimed

      3. 366.Effect where credit for release brought into account on amortised cost basis

      4. 367.Reduction of credits exceeding impairment losses

      5. 368.Reduction of claims where there are earlier net consortium debits

      6. 369.Carry forward of claims where there are no net consortium debits

      7. 370.Group accounting periods

      8. 371.Interpretation

    8. Chapter 8 Connected parties relationships: late interest

      1. 372.Introduction to Chapter

      2. 373.Late interest treated as not accruing until paid in some cases

      3. 374.Connection between debtor and person standing in position of creditor

      4. 375.Loans to close companies by participators etc

      5. 376.Interpretation of section 375

      6. 377.Party to loan relationship having major interest in other party

      7. 378.Loans by trustees of occupational pension schemes

      8. 379.Persons indirectly standing in the position of creditor

    9. Chapter 9 Partnerships involving companies

      1. 380.Partnerships involving companies

      2. 381.Determinations of credits and debits by company partners: general

      3. 382.Company partners using fair value accounting

      4. 383.Lending between partners and the partnership

      5. 384.Treatment of exchange gains and losses

      6. 385.Company partners' shares where firm owns deeply discounted securities

    10. Chapter 10 Insurance companies

      1. Introduction

        1. 386.Overview of Chapter

      2. Treatment of deficit on basic life assurance and general annuity business

        1. 387.Treatment of deficit on basic life assurance and general annuity business: introduction

        2. 388.Basic rule: deficit set off against income and gains of deficit period

        3. 389.Claim to carry back deficit

        4. 390.Meaning of “available profits”

        5. 391.Carry forward of surplus deficit to next accounting period

      3. Exclusion of loan relationships of members of Lloyd's

        1. 392.Exclusion of loan relationships of members of Lloyd's

      4. Determination of questions requiring apportionments

        1. 393.General rules for some debtor relationships

        2. 394.Special rules for some debtor relationships

    11. Chapter 11 Other special kinds of company

      1. Investment trusts' and venture capital trusts' creditor relationships

        1. 395.Investment trusts: profits or losses of a capital nature

        2. 396.Venture capital trusts: profits or losses of a capital nature

      2. Credit unions

        1. 397.Credit unions

    12. Chapter 12 Special rules for particular kinds of securities

      1. Introduction

        1. 398.Overview of Chapter

      2. Gilt-edged securities

        1. 399.Index-linked gilt-edged securities: basic rules

        2. 400.Index-linked gilt-edged securities: adjustments for changes in index

        3. 401.Gilt strips

        4. 402.Market value of securities

        5. 403.Meaning of “strip”

        6. 404.Restriction on deductions etc relating to FOTRA securities

        7. 405.Certain non-UK residents with interest on 3½% War Loan 1952 Or After

      3. Deeply discounted securities: connected companies and close companies

        1. 406.Introduction

        2. 407.Postponement until redemption of debits for connected companies' deeply discounted securities

        3. 408.Companies connected for section 407

        4. 409.Postponement until redemption of debits for close companies' deeply discounted securities

        5. 410.Exceptions to section 409

        6. 411.Interpretation of section 409

        7. 412.Persons indirectly standing in the position of creditor

      4. Funding bonds

        1. 413.Issue of funding bonds

        2. 414.Redemption of funding bonds

      5. Derivatives

        1. 415.Loan relationships with embedded derivatives

        2. 416.Election for application of sections 415 and 585

        3. 417.Further provisions about elections under section 416

        4. 418.Loan relationships involving connected debtor and creditor where debits exceed credits

        5. 418A.Cases involving host contract

        6. 419.Section 418: supplementary

      6. Options etc

        1. 420.Assumptions where options etc apply

    13. Chapter 13 European cross-border transfers of business

      1. Introduction

        1. 421.Introduction to Chapter

      2. Transfers of loan relationships at notional carrying value

        1. 422.Transfer of loan relationship at notional carrying value

        2. 423.Transferor using fair value accounting

        3. 424.Reorganisations involving loan relationships

        4. 425.Original holder using fair value accounting

      3. Exception for tax avoidance cases

        1. 426.Tax avoidance etc

        2. 427.Procedure on application for clearance

        3. 428.Decision on application for clearance

      4. Transparent entities

        1. 429.Disapplication of Chapter where transparent entities involved

      5. Interpretation

        1. 430.Interpretation

    14. Chapter 14 European cross-border mergers

      1. Introduction

        1. 431.Introduction to Chapter

        2. 432.Meaning of “the transferee” and “transferor”

      2. Transfers of loan relationships at notional carrying value

        1. 433.Transfer of loan relationship at notional carrying value

        2. 434.Transferor using fair value accounting

        3. 435.Reorganisations involving loan relationships

        4. 436.Original holder using fair value accounting

      3. Exception for tax avoidance cases

        1. 437.Tax avoidance etc

      4. Transparent entities

        1. 438.Disapplication of Chapter where transparent entities involved

      5. Interpretation

        1. 439.Interpretation

    15. Chapter 15 Tax avoidance

      1. Introduction

        1. 440.Overview of Chapter

      2. Unallowable purposes and tax relief schemes

        1. 441.Loan relationships for unallowable purposes

        2. 442.Meaning of “unallowable purpose”

        3. 443.Restriction of relief for interest where tax relief schemes involved

      3. Transactions not at arm's length: general

        1. 444.Transactions not at arm's length: general

        2. 445.Disapplication of section 444 where Part 4 of TIOPA 2010 applies

        3. 446.Bringing into account adjustments made under Part 4 of TIOPA 2010

      4. Transactions not at arm's length: exchange gains and losses

        1. 447.Exchange gains and losses on debtor relationships: loans disregarded under Part 4 of TIOPA 2010

        2. 448.Exchange gains and losses on debtor relationships: equity notes where holder associated with issuer

        3. 449.Exchange gains and losses on creditor relationships: no corresponding debtor relationship

        4. 450.Meaning of “corresponding debtor relationship”

        5. 451.Exception to section 449 where loan exceeds arm's length amount

        6. 452.Exchange gains and losses where loan not on arm's length terms

      5. Connected parties deriving benefit from creditor relationships

        1. 453.Connected parties deriving benefit from creditor relationships

      6. Tax advantages from resetting interest rates (“reset bonds”)

        1. 454.Application of fair value accounting: reset bonds etc

      7. Disposals for consideration not fully recognised by accounting practice

        1. 455.Disposals for consideration not fully recognised by accounting practice

    16. Chapter 16 Non-trading deficits

      1. 456.Introduction to Chapter

      2. 457.Basic rule for deficits: carry forward to accounting periods after deficit period

      3. 458.Claim to carry forward deficit to later accounting periods

      4. 459.Claim to set off deficit against profits of deficit period or earlier periods

      5. 460.Time limits and procedure for claims under section 459(1)

      6. 461.Claim to set off deficit against other profits for the deficit period

      7. 462.Claim to carry back deficit to earlier accounting periods

      8. 463.Profits available for relief under section 462

    17. Chapter 17 Priority rules

      1. 464.Priority of this Part for corporation tax purposes

      2. 465.Exclusion of distributions except in tax avoidance cases

    18. Chapter 18 General and supplementary provisions

      1. Connections between persons

        1. 466.Companies connected for an accounting period

        2. 467.Connections where partnerships are involved

        3. 468.Connection between companies to be ignored in some circumstances

        4. 469.Creditors who are financial traders

        5. 470.Section 469: supplementary provisions

        6. 471.Creditors who are insurance companies carrying on BLAGAB

        7. 472.Meaning of “control”

        8. 473.Meaning of “major interest”

        9. 474.Treatment of connected companies and partnerships for section 473

        10. 475.Meaning of expressions relating to exchange gains and losses

      2. Other general definitions

        1. 476.Other definitions

  7. Part 6 Relationships treated as loan relationships etc

    1. Chapter 1 Introduction

      1. 477.Overview of Part

    2. Chapter 2 Relevant non-lending relationships

      1. Introduction: meaning of “relevant non-lending relationship” etc

        1. 478.Relevant non-lending relationships: introduction

        2. 479.Relevant non-lending relationships not involving discounts

        3. 480.Relevant non-lending relationships involving discounts

      2. Application of Part 5 to relevant non-lending relationships

        1. 481.Application of Part 5 to relevant non-lending relationships

        2. 482.Miscellaneous rules about amounts to be brought into account because of this Chapter

      3. Meaning of “money debt” and “interest” in this Chapter

        1. 483.Exchange gains and losses: amounts treated as money debts

        2. 484.Provision not at arm's length: meaning of “interest” and “money debt”

      4. Exclusions

        1. 485.Exclusion of debts where profits or losses within Part 7 or 8

        2. 486.Exclusion of exchange gains and losses in respect of tax debts etc

    3. Chapter 2A Disguised interest

      1. 486A.Overview

      2. 486B.Disguised interest to be regarded as profit from loan relationship

      3. 486C.Exclusion where return otherwise taxable

      4. 486D.Exclusion where arrangement has no tax avoidance purpose

      5. 486E.Excluded shares

    4. Chapter 2B Transferred income streams

      1. 486F.Introduction to Chapter

      2. 486G.Consideration to be treated as loan relationship

    5. Chapter 3 OEICs, unit trusts and offshore funds

      1. Introduction

        1. 487.Overview of Chapter

        2. 488.Meaning of “open-ended investment company” etc

        3. 489.Meaning of “offshore fund” etc

      2. Holdings in OEICs, unit trusts and offshore funds treated as creditor relationship rights

        1. 490.Holdings in OEICs, unit trusts and offshore funds treated as creditor relationship rights

        2. 491.Holding coming within section 490: opening valuations

        3. 492.Disregard of investments made and liabilities incurred with avoidance intention etc

      3. The qualifying investments test

        1. 493.The qualifying investments test

        2. 494.Meaning of “qualifying investments”

        3. 495.Qualifying holdings

        4. 496.Meaning of “hedging relationship”

      4. Power to change investments that are qualifying investments

        1. 497.Power to change investments that are qualifying investments

    6. Chapter 4 Building Societies

      1. 498.Building society dividends and interest

    7. Chapter 5 Industrial and provident societies

      1. 499.Industrial and provident society payments treated as interest under loan relationship

      2. 500.Exclusion of interest where failure to make return

    8. Chapter 6 Alternative finance arrangements

      1. Introduction

        1. 501.Introduction to Chapter

        2. 502.Meaning of “financial institution”

      2. Arrangements that are alternative finance arrangements

        1. 503.Purchase and resale arrangements

        2. 504.Diminishing shared ownership arrangements

        3. 505.Deposit arrangements

        4. 506.Profit share agency arrangements

        5. 507.Investment bond arrangements

        6. 508.Provision not at arm's length: exclusion of arrangements from sections 503 to 507

      3. Treatment as loan relationships

        1. 509.Application of Part 5: general

        2. 510.Application of Part 5 to particular alternative finance arrangements

      4. Meaning of “alternative finance return”

        1. 511.Purchase and resale arrangements

        2. 512.Diminishing shared ownership arrangements

        3. 513.Other arrangements

      5. Treatment for other tax purposes

        1. 514.Exclusion of alternative finance return from consideration for sale of assets

        2. 515.Diminishing shared ownership arrangements not partnerships

        3. 516.Treatment of principal under profit sharing agency arrangements

        4. 517.Treatment of bond-holder under investment bond arrangements

        5. 518.Investment bond arrangements: treatment as securities

        6. 519.Investment bond arrangements: other provisions

        7. 520.Provision not at arm's length: non-deductibility of relevant return

      6. Power to extend this Chapter to other arrangements

        1. 521.Power to extend this Chapter to other arrangements

    9. Chapter 6A Shares accounted for as liabilities

      1. 521A.Introduction to Chapter

      2. 521B.Application of Part 5 to certain shares as rights under creditor relationship

      3. 521C.Shares accounted for as liabilities

      4. 521D.Excepted shares

      5. 521E.Unallowable purpose

      6. 521F.Shares becoming or ceasing to be shares to which section 521B applies

    10. Chapter 7 Shares with guaranteed returns etc

      1. ...

        1. 522.Introduction to Chapter

        2. 523.Application of Part 5 to certain shares as rights under creditor relationship

      2. ...

        1. 524.Shares subject to outstanding third party obligations

        2. 525.Meaning of “interest-like investment”

      3. ...

        1. 526.Non-qualifying shares

        2. 527.The increasing value condition

        3. 528.Regulations about income-producing assets

        4. 529.The redemption return condition

        5. 530.The redemption return condition: excepted shares

        6. 531.The redemption return condition: unallowable purposes

        7. 532.The associated transactions condition

        8. 533.Power to change conditions for non-qualifying shares

      4. ...

        1. 534.Amounts to be brought into account where section 523 applies

        2. 535.Shares ceasing to be shares to which section 523 applies

    11. Chapter 8

      1. 536.Introduction to Chapter

      2. 537.Payments in return for capital contribution to partnership

      3. 538.Change of partnership shares

    12. Chapter 9 Manufactured interest etc

      1. 539.Introduction to Chapter

      2. 540.Manufactured interest treated as interest under loan relationship

      3. 541.Debits for deemed interest under stock lending arrangements disallowed

    13. Chapter 10 Repos

      1. Introduction

        1. 542.Introduction to Chapter

      2. Creditor repos and creditor quasi-repos

        1. 543.Meaning of creditor repo

        2. 544.Meaning of creditor quasi-repo

        3. 545.Ignoring effect on lender etc of sale of securities

        4. 546.Charge on lender for finance return in respect of the advance

        5. 547.Repo under arrangement designed to produce quasi-interest: tax avoidance

      3. Debtor repos and debtor quasi-repos

        1. 548.Meaning of debtor repo

        2. 549.Meaning of debtor quasi-repo

        3. 550.Ignoring effect on borrower of sale of securities

        4. 551.Relief for borrower for finance charges in respect of the advance

      4. General provisions

        1. 552.General provisions about arrangements

        2. 553.Persons buying or selling for others

        3. 554.Power to modify this Chapter

        4. 555.Cases where section 554 applies: non-standard repos

      5. Interpretation

        1. 556.Meaning of securities and similar securities

        2. 557.Meaning of person receiving an asset

        3. 558.Interpretation of accounting expressions

        4. 559.Minor definitions

    14. Chapter 11 Investment life insurance contracts

      1. Introduction

        1. 560.Introduction to Chapter

        2. 561.Meaning of “investment life insurance contract”

      2. Investment life assurance contracts treated as creditor relationships

        1. 562.Contract to be loan relationship

        2. 563.Increased non-trading credits for BLAGAB and EEA taxed contracts

        3. 564.Section 563: interpretation

        4. 565.Relevant amount where the relevant company uses fair value accounting

      3. Old accounting period contracts

        1. 566.Introduction

        2. 567.Gains on deemed surrenders to be brought into account on related transactions

        3. 568.Restriction on credits on old contracts: fair value accounting cases

        4. 569.Restriction on debits on old contracts: non-fair value accounting cases

  8. Part 7 Derivative contracts

    1. Chapter 1 Introduction

      1. Introduction

        1. 570.Overview of Part

      2. How profits and losses from derivative contracts are dealt with

        1. 571.General rule: profits chargeable as income

        2. 572.Profits and losses to be calculated using credits and debits given by this Part

        3. 573.Trading credits and debits to be brought into account under Part 3

        4. 574.Non-trading credits and debits to be brought into account under Part 5

    2. Chapter 2 Contracts to which this Part applies

      1. Introduction

        1. 575.Overview of Chapter

      2. Meaning of “derivative contract” and other basic definitions

        1. 576.“Derivative contract”

        2. 577.“Relevant contract”

        3. 578.Relevant contracts of a company and being party to such contracts

        4. 579.The accounting conditions

        5. 580.“Option”

        6. 581.“Future”

        7. 582.“Contract for differences”

        8. 583.“Underlying subject matter”

      3. Cases where companies treated as parties to relevant contracts

        1. 584.Hybrid derivatives with embedded derivatives

        2. 585.Loan relationships with embedded derivatives

        3. 586.Other contracts with embedded derivatives

      4. Other contracts etc treated as derivative contracts

        1. 587.Contract relating to holding in OEIC, unit trust or offshore fund

        2. 588.Associated transaction treated as derivative contract

      5. Exclusions from derivative contracts

        1. 589.Contracts excluded because of underlying subject matter: general

        2. 590.Disregard of subordinate or small value underlying subject matter

        3. 591.Conditions A to E mentioned in section 589(5)

        4. 592.Embedded derivatives treated as meeting condition in section 591 etc

        5. 593.Contracts where part of underlying subject matter is excluded property

    3. Chapter 3 Credits and debits to be brought into account: general

      1. Introduction

        1. 594.Overview of Chapter

      2. General principles

        1. 595.General principles about the bringing into account of credits and debits

        2. 596.Meaning of “related transaction”

      3. Amounts recognised in determining a company's profit or loss

        1. 597.Amounts recognised in determining a company's profit or loss

        2. 598.Regulations about recognised amounts

        3. 599.Meaning of “amounts recognised for accounting purposes”

        4. 599A.Amounts not fully recognised for accounting purposes: introduction

        5. 599B.Determination of credits and debits where amounts not fully recognised

      4. Application of fair value accounting

        1. 600.Contract which is or forms part of financial asset or liability

        2. 601.Contract relating to holding in OEIC, unit trust or offshore fund

        3. 602.Contract becoming one relating to holding in OEIC, unit trust or offshore fund

        4. 603.Associated transaction treated as derivative contract

      5. Rules differing from generally accepted accounting practice

        1. 604.Credits and debits treated as relating to capital expenditure

        2. 605.Credits and debits recognised in equity

      6. Exchange gains and losses

        1. 606.Exchange gains and losses

        2. 606A.Arrangements that have a “one-way exchange effect”

        3. 606B.Meaning of “relevant exchange gain” and “relevant exchange loss”

        4. 606C.Meaning of “test day”

        5. 606D.Counterfactual currency movement assumptions

        6. 606E.Counterfactual currency movement assumptions: treatment of options

        7. 606F.Meaning of “option”

        8. 606G.Meaning of “relevant contingent contract” and “operative condition”

        9. 606H.Other interpretative provisions

      7. Miscellaneous

        1. 607.Pre-contract or abortive expenses

        2. 608.Company ceasing to be party to derivative contract

        3. 609.Company ceasing to be UK resident

        4. 610.Non-UK resident company ceasing to hold derivative contract for UK permanent establishment

        5. 611.Release under statutory insolvency arrangement of liability under derivative contract

    4. Chapter 4 Further provision about credits and debits to be brought into account

      1. Introduction

        1. 612.Overview of Chapter

      2. Adjustments on change of accounting policy

        1. 613.Introduction to sections 614 and 615

        2. 614.Change of accounting policy involving change of value

        3. 615.Change of accounting policy after ceasing to be party to derivative contract

      3. Certain embedded derivatives

        1. 616.Disapplication of fair value accounting

        2. 617.Election for section 616 not to apply

        3. 618.Elections under section 617: groups of companies

      4. Partnerships involving companies

        1. 619.Partnerships involving companies

        2. 620.Determination of credits and debits by company partners

        3. 621.Company partners using fair value accounting

      5. Miscellaneous

        1. 622.Contracts ceasing to be derivative contracts

        2. 623.Index-linked gilt-edged securities with embedded contracts for differences

    5. Chapter 5 Continuity of treatment on transfers within groups

      1. Introductory

        1. 624.Introduction to Chapter

      2. Group member replacing another as party to derivative contract

        1. 625.Group member replacing another as party to derivative contract

        2. 626.Transactions to which section 625 applies

        3. 627.Meaning of company replacing another as party to derivative contract

      3. Exceptions to section 625

        1. 628.Transferor using fair value accounting

        2. 629.Tax avoidance

      4. Transferee leaving group after replacing transferor as party to derivative contract

        1. 630.Introduction to sections 631 and 632

        2. 631.Transferee leaving group otherwise than because of exempt distribution

        3. 632.Transferee leaving group because of exempt distribution

    6. Chapter 6 Special kinds of company

      1. Mutual trading companies

        1. 633.Mutual trading companies

      2. Insurance companies

        1. 634.Insurance companies

        2. 635.Creditor relationships: embedded derivatives which are options

        3. 636.Modifications of Chapter 5

      3. Investment and venture capital trusts

        1. 637.Investment trusts: profits or losses of a capital nature

        2. 638.Venture capital trusts: profits or losses of a capital nature

    7. Chapter 7 Chargeable gains arising in relation to derivative contracts

      1. Introduction

        1. 639.Overview of Chapter

      2. Some credits and debits not to be brought into account under Part 5

        1. 640.Credits and debits not to be brought into account under Part 5

      3. Some derivative contracts to be taxed on a chargeable gains basis

        1. 641.Derivative contracts to be taxed on a chargeable gains basis

        2. 642.Exception from section 641

      4. Derivative contracts to which sections 640 and 641 apply

        1. 643.Contracts relating to land or certain tangible movable property

        2. 644.Income to be left out of account in determining whether section 643 applies

        3. 645.Creditor relationships: embedded derivatives which are options

        4. 646.Exclusions from section 645

        5. 647.Meaning of certain expressions in section 645

        6. 648.Creditor relationships: embedded derivatives which are exactly tracking contracts for differences

        7. 649.Meaning of certain expressions in section 648

        8. 650.Property based total return swaps

      5. Some credits and debits not to be brought into account under Part 3 or 5

        1. 651.Credits and debits not to be brought into account under Part 3 or Part 5

      6. Issuers of securities with embedded derivatives: deemed options

        1. 652.Introduction to sections 653 to 655

        2. 653.Shares issued or transferred as a result of exercise of deemed option

        3. 654.Payment instead of disposal on exercise of deemed option

        4. 655.Ceasing to be party to debtor relationship when deemed option not exercised

      7. Issuers of securities with embedded derivatives: deemed contracts for differences

        1. 656.Introduction to section 658

        2. 657.Meaning of “exactly tracking contract” in section 656

        3. 658.Chargeable gain or allowable loss treated as accruing

      8. Interpretation

        1. 659.Meaning of “relevant credits” and “relevant debits”

    8. Chapter 8 Further provision about chargeable gains and derivative contracts

      1. Company ceasing to be party to certain contracts

        1. 660.Contract relating to holding in OEIC, unit trust or offshore fund

        2. 661.Contract which becomes derivative contract

      2. Contracts ceasing to be derivative contracts

        1. 662.Contracts ceasing to be derivative contracts

      3. Carry back of net losses on certain derivative contracts

        1. 663.Contracts to which section 641 applies

        2. 664.Meaning of certain expressions in section 663

      4. Issuers of securities with embedded derivatives: equity instruments

        1. 665.Introduction to section 666

        2. 666.Allowable loss treated as accruing

      5. Treatment of shares acquired in certain circumstances

        1. 667.Shares acquired on exercise of non-embedded option

        2. 668.Shares acquired on running of future to delivery

        3. 669.Meaning of G and L in sections 667 and 668

      6. Treatment of net gains and losses on exercise of option

        1. 670.Treatment of net gains and losses on exercise of option

        2. 671.Meaning of G, L and CV in section 670

      7. Treatment of net gains and losses on disposal of certain embedded derivatives

        1. 672.Treatment of net gains and losses on disposal of certain embedded derivatives

        2. 673.Meaning of G, L and CV in section 672

    9. Chapter 9 European cross-border transfers of business

      1. Introduction

        1. 674.Introduction to Chapter

      2. Transfers of derivative contracts at notional carrying value

        1. 675.Transfer of derivative contract at notional carrying value

        2. 676.Transferor using fair value accounting

      3. Exception for tax avoidance cases and clearances

        1. 677.Tax avoidance etc

        2. 678.Procedure on application for clearance

        3. 679.Decision on application for clearance

      4. Transparent entities

        1. 680.Disapplication of Chapter where transparent entities involved

      5. Interpretation

        1. 681.Interpretation

    10. Chapter 10 European cross-border mergers

      1. Introduction

        1. 682.Introduction to Chapter

        2. 683.Meaning of “the transferee” and “transferor”

      2. Transfers of derivative contracts at notional carrying value

        1. 684.Transfer of derivative contract at notional carrying value

        2. 685.Transferor using fair value accounting

      3. Exception for tax avoidance cases and clearances

        1. 686.Tax avoidance etc

      4. Transparent entities

        1. 687.Disapplication of Chapter where transparent entities involved

      5. Interpretation

        1. 688.Interpretation

    11. Chapter 11 Tax avoidance

      1. Introduction

        1. 689.Overview of Chapter

      2. Unallowable purposes

        1. 690.Derivative contracts for unallowable purposes

        2. 691.Meaning of “unallowable purpose”

        3. 692.Allowance of accumulated net losses

      3. Transactions not at arm's length

        1. 693.Bringing into account adjustments under Part 4 of TIOPA 2010

        2. 694.Exchange gains and losses

        3. 695.Transfers of value to connected companies

      4. Transactions with non-UK residents

        1. 696.Derivative contracts with non-UK residents

        2. 697.Exceptions to section 696

      5. Disposals for consideration not fully recognised by accounting practice

        1. 698.Disposals for consideration not fully recognised by accounting practice

    12. Chapter 12 Priority rules

      1. 699.Priority of this Part for corporation tax purposes

      2. 700.Relationship of this Part to Part 5: loan relationships

    13. Chapter 13 General and supplementary provisions

      1. Power to amend certain provisions

        1. 701.Power to amend some provisions

      2. Other general definitions

        1. 702.“Carrying value”

        2. 703.“Chargeable asset”

        3. 704.“Creditor relationship” and “debtor relationship”

        4. 705.Expressions relating to exchange gains and losses

        5. 706.“Excluded body”

        6. 707.“Hedging relationship”

        7. 708.“Plain vanilla contract”

        8. 709.“Securities house”

        9. 710.Other definitions

  9. Part 8 Intangible fixed assets

    1. Chapter 1 Introduction

      1. Introductory

        1. 711.Overview of Part

      2. Basic definitions

        1. 712.“Intangible asset”

        2. 713.“Intangible fixed asset”

        3. 714.“Royalty”

      3. Goodwill

        1. 715.Application of this Part to goodwill

      4. Accounting rules and definitions

        1. 716.“Recognised” amounts and “GAAP-compliant accounts”

        2. 717.Companies without GAAP-compliant accounts

        3. 718.GAAP-compliant accounts: reference to consolidated group accounts

        4. 719.Accounting value

    2. Chapter 2 Credits in respect of intangible fixed assets

      1. 720.Introduction

      2. 721.Receipts recognised as they accrue

      3. 722.Receipts in respect of royalties so far as not dealt with under section 721

      4. 723.Revaluation

      5. 724.Negative goodwill

      6. 725.Reversal of previous accounting loss

    3. Chapter 3 Debits in respect of intangible fixed assets

      1. 726.Introduction

      2. 727.References to expenditure on an asset

      3. 728.Expenditure written off as it is incurred

      4. 729.Writing down on accounting basis

      5. 730.Writing down at fixed rate: election for fixed-rate basis

      6. 731.Writing down at fixed rate: calculation

      7. 732.Reversal of previous accounting gain

    4. Chapter 4 Realisation of intangible fixed assets

      1. 733.Overview of Chapter

      2. 734.Meaning of “realisation”

      3. 735.Asset written down for tax purposes

      4. 736.Asset shown in balance sheet and not written down for tax purposes

      5. 737.Apportionment in case of part realisation

      6. 738.Asset not shown in balance sheet

      7. 739.Meaning of “proceeds of realisation”

      8. 740.Abortive expenditure on realisation

      9. 741.Meaning of “chargeable intangible asset” and “chargeable realisation gain”

    5. Chapter 5 Calculation of tax written-down value

      1. 742.Asset written down on accounting basis

      2. 743.Asset written down at fixed rate

      3. 744.Effect of part realisation of asset

    6. Chapter 6 How credits and debits are given effect

      1. Introductory

        1. 745.Introduction

        2. 746.“Non-trading credits” and “non-trading debits”

      2. Trading etc credits and debits

        1. 747.Assets held for purposes of trade

        2. 748.Assets held for purposes of property business

        3. 749.Assets held for purposes of mines, transport undertakings, etc

        4. 750.Assets held for purposes falling within more than one section

      3. Non-trading credits and debits

        1. 751.Non-trading gains and losses

        2. 752.Charge to tax on non-trading gains on intangible fixed assets

        3. 753.Treatment of non-trading losses

    7. Chapter 7 Roll-over relief in case of realisation and reinvestment

      1. When the relief is given

        1. 754.The relief: the “old asset” and “other assets”

        2. 755.Conditions relating to the old asset and its realisation

        3. 756.Conditions relating to expenditure on other assets

        4. 757.Claim for relief

      2. How the relief is given

        1. 758.How the relief is given: general

        2. 759.Determination of appropriate proportion of cost and adjusted cost

        3. 760.References to cost of asset where asset affected by change of accounting policy

        4. 761.Declaration of provisional entitlement to relief

        5. 762.Realisation and reacquisition

        6. 763.Disregard of deemed realisations and reacquisitions

    8. Chapter 8 Groups of companies: introduction

      1. Introductory

        1. 764.Meaning of “company”, “group” and “subsidiary”

      2. Rules

        1. 765.General rule: a company and its 75% subsidiaries form a group

        2. 766.Only effective 51% subsidiaries of principal company to be members of group

        3. 767.Principal company cannot be 75% subsidiary of another company

        4. 768.Company cannot be member of more than one group

        5. 769.Continuity of identity of group

        6. 770.Continuity where group includes an SE

        7. 771.Meaning of “effective 51% subsidiary”

        8. 772.Equity holders and profits or assets available for distribution

        9. 773.Supplementary provisions

    9. Chapter 9 Application of this Part to groups of companies

      1. Introductory

        1. 774.Overview of Chapter

      2. Transfers within a group treated as tax-neutral

        1. 775.Transfers within a group

        2. 776.Meaning of “tax-neutral” transfer

      3. Roll-over relief under Chapter 7 (realisation and reinvestment)

        1. 777.Relief on realisation and reinvestment: application to group member

        2. 778.Relief on reinvestment: acquisition of group company: introduction

        3. 779.Rules that apply to cases within section 778(1)

      4. Company ceasing to be member of group

        1. 780.Deemed realisation and reacquisition at market value

        2. 781.Character of credits and debits brought into account as a result of section 780

        3. 782.Certain transferees of businesses etc not treated as leaving group

        4. 783.Associated companies leaving group at the same time

        5. 784.Groups with a relevant connection

        6. 785.Principal company becoming member of another group

        7. 786.Character of credits and debits brought into account as a result of section 785

        8. 787.Company ceasing to be member of group because of exempt distribution

        9. 788.Provisions supplementing sections 780 to 787

        10. 789.Merger carried out for genuine commercial reasons

        11. 790.Provisions supplementing section 789

        12. 791.Application of roll-over relief in relation to degrouping charge

      5. Reallocation of degrouping charge within group and recovery

        1. 792.Reallocation of charge within group

        2. 793.Further requirements about elections under section 792

        3. 794.Application of roll-over relief in relation to reallocated charge

        4. 795.Recovery of charge from another group company or controlling director

        5. 796.Interpretation of section 795

        6. 797.Recovery under section 795: procedure etc

        7. 798.Recovery under section 795: time limit

      6. Disregard of payments between group members for reliefs

        1. 799.Disregard of payments between group members for reliefs

    10. Chapter 10 Excluded assets

      1. Introductory

        1. 800.Introduction

        2. 801.Right to dispose of or acquire excluded asset also excluded

        3. 802.Effect of partial exclusion

      2. Assets wholly excluded from this Part

        1. 803.Non-commercial purposes etc

        2. 804.Assets for which capital allowances previously made

        3. 805.Rights over tangible assets

        4. 806.Financial assets

        5. 807.Rights in companies, trusts etc

        6. 808.Assets representing production expenditure on films

        7. 809.Oil licences

      3. Assets excluded from this Part except as respects royalties

        1. 810.Mutual trade or business

        2. 811.Sound recordings

        3. 812.Master versions of films

        4. 813.Computer software treated as part of cost of related hardware

      4. Assets excluded from this Part to the extent specified

        1. 814.Research and development

        2. 815.Election to exclude capital expenditure on software

        3. 816.Further provision about elections under section 815

    11. Chapter 11 Transfer of business or trade

      1. Introduction

        1. 817.Overview of Chapter

      2. Tax-neutral transfers

        1. 818.Company reconstruction involving transfer of business

        2. 819.European cross-border transfers of business: introduction

        3. 820.Transfer of assets on European cross-border transfer of business

        4. 821.European cross-border mergers: introduction

        5. 822.Transfer of assets on European cross-border merger

        6. 823.Interpretation of sections 821 and 822

        7. 824.Transfer of business of building society to company

        8. 825.Application of sections 780 and 785 where transfer within section 824 occurs

        9. 826.Amalgamation of, or transfer of engagements by, certain societies

      3. Transfer of assets to non-UK resident company

        1. 827.Claims to postpone charge on transfer

        2. 828.Relief on transfer

        3. 829.Charge on subsequent realisations

        4. 830.Exclusion from section 829 of group transfers

      4. The genuine commercial transaction requirement and clearance

        1. 831.The genuine commercial transaction requirement and clearance

        2. 832.Procedure on application for clearance

        3. 833.Decision on application for clearance

    12. Chapter 12 Related parties

      1. Introductory

        1. 834.Overview of Chapter

      2. Meaning of “related party”, “control” and “major interest”

        1. 835.“Related party”

        2. 836.“Control”

        3. 837.“Major interest”

      3. Rights and powers to be taken into account

        1. 838.General rule

        2. 839.Rights and powers held jointly

        3. 840.Partnerships

      4. Meaning of “participator” and “associate”

        1. 841.“Participator” and “associate”

      5. Connected persons

        1. 842.Introduction

        2. 843.Who are connected persons

    13. Chapter 13 Transactions between related parties

      1. Introductory

        1. 844.Overview of Chapter

      2. Transfers treated as being at market value

        1. 845.Transfer between company and related party treated as at market value

        2. 846.Transfers not at arm's length

        3. 847.Transfers involving other taxes

        4. 848.Tax-neutral transfers

        5. 849.Transfers involving gifts of business assets

      3. Other rules

        1. 850.Part realisation involving related party acquisition: exclusion of roll-over relief

        2. 851.Delayed payment of royalty by company to related party

    14. Chapter 14 Miscellaneous provisions

      1. Grants and other contributions to expenditure

        1. 852.Treatment of grants and other contributions to expenditure

        2. 853.Grants to be left out of account for tax purposes

      2. Finance leasing

        1. 854.Finance leasing etc

        2. 855.Further provision about regulations under section 854

      3. Values to be used in special cases

        1. 856.Assets acquired or realised together

        2. 857.Deemed market value acquisition: adjustment where nil accounting value

      4. Fungible assets

        1. 858.Fungible assets

      5. Assets ceasing to be or becoming chargeable intangible assets

        1. 859.Asset ceasing to be chargeable intangible asset: deemed realisation at market value

        2. 860.Asset ceasing to be chargeable intangible asset: postponement of gain

        3. 861.Treatment of postponed gain on subsequent realisation

        4. 862.Treatment of postponed gain in other cases

        5. 863.Asset becoming chargeable intangible asset

      6. Matters to be ignored

        1. 864.Tax avoidance arrangements to be ignored

        2. 865.Debits for expenditure not generally deductible for tax purposes

      7. Delayed payments and bad debts

        1. 866.Delayed payment of employees' remuneration

        2. 867.Provisions supplementing section 866

        3. 868.Delayed payment of pension contributions

        4. 869.Bad debts etc

      8. Controlled foreign companies

        1. 870.Assumptions for calculating chargeable profits

    15. Chapter 15 Adjustments on change of accounting policy

      1. Introductory

        1. 871.Introduction to Chapter

      2. Change of policy involving change of value

        1. 872.Adjustments in respect of change

        2. 873.Effect of application of section 872 in later period and subsequently

      3. Change of policy involving disaggregation

        1. 874.Original asset not subject to fixed-rate writing down

        2. 875.Effect of application of section 874 in later period and subsequently

        3. 876.Original asset subject to fixed-rate writing down

        4. 877.Election for fixed-rate writing down in relation to resulting asset

      4. Supplementary

        1. 878.Exclusion of credits or debits brought into account under other provisions

        2. 879.Subsequent events affecting asset subject to adjustment under this Chapter

    16. Chapter 16 Pre-FA 2002 assets etc

      1. Introduction

        1. 880.Overview of Chapter

        2. 881.Meaning of “pre-FA 2002 assets”

      2. General rule

        1. 882.Application of this Part to assets created or acquired on or after 1 April 2002

      3. When assets are treated as created or acquired

        1. 883.Assets treated as created or acquired when expenditure incurred

        2. 884.... goodwill: time of creation

        3. 885.Assets representing non-qualifying expenditure: time of creation

        4. 886.Assets representing production expenditure on films: time of creation

      4. When expenditure treated as incurred

        1. 887.General rule

        2. 888.Cases where chargeable gains rule applies

        3. 889.Cases where capital allowances general rule applies

      5. Fungible assets

        1. 890.Fungible assets: application of section 858

        2. 891.Realisation and acquisition of fungible assets

      6. Assets treated as pre-FA 2002 assets

        1. 892.Certain assets acquired on transfer of business

        2. 893.Assets whose value derives from pre-FA 2002 assets

        3. 894.The preserved status conditions etc

        4. 895.Assets acquired in connection with disposals of pre-FA 2002 assets

      7. Application of Part to royalties and telecommunication rights

        1. 896.Application to royalties

        2. 897.Application to pre-FA 2002 assets consisting of telecommunication rights

      8. Roll-over relief for disposals of pre-FA 2002 assets

        1. 898.Relief where assets disposed of on or after 1 April 2002

        2. 899.Relief where degrouping charge on asset arises on or after 1 April 2002

        3. 900.Meaning of “chargeable asset within TCGA” in sections 898 and 899

    17. Chapter 17 Insurance companies

      1. Effect of application of the I minus E basis: non-trading amounts

        1. 901.Effect of application of the I minus E basis: non-trading amounts

      2. Excluded assets and computer software

        1. 902.Excluded assets

        2. 903.Elections to exclude capital expenditure on computer software

      3. Miscellaneous

        1. 904.Transfers of life assurance business: transfers of assets treated as tax-neutral

        2. 905.Pre-FA 2002 assets: Lloyd's syndicate capacity

    18. Chapter 18 Priority rules

      1. 906.Priority of this Part for corporation tax purposes

  10. Part 9 Intellectual property: know-how and patents

    1. Chapter 1 Introduction

      1. 907.Overview of Part

    2. Chapter 2 Disposals of know-how

      1. 908.Charge to tax on profits from disposals of know-how

      2. 909.Exceptions to charge under section 908

      3. 910.Profits charged under section 908

    3. Chapter 3 Sales of patent rights

      1. Introductory

        1. 911.Overview of Chapter

      2. Charge to tax

        1. 912.Charge to tax on profits from sales of patent rights

        2. 913.Profits charged under section 912

      3. Spreading of charge to tax

        1. 914.UK resident companies: proceeds of sale not received in instalments

        2. 915.UK resident companies: proceeds of sale received in instalments

        3. 916.Non-UK resident companies: proceeds of sale not received in instalments

        4. 917.Non-UK resident companies: proceeds of sale received in instalments

        5. 918.Winding up of a body corporate

      4. Miscellaneous

        1. 919.Deduction of tax from payments to non-UK resident companies

        2. 920.Adjustments where tax has been deducted

        3. 921.Licences connected with patents

        4. 922.Rights to acquire future patent rights

        5. 923.Sums paid for Crown use etc treated as paid under licence

    4. Chapter 4 Relief from corporation tax on patent income

      1. 924.Relief for expenses: patent income

      2. 925.How relief is given under section 924

    5. Chapter 5 Supplementary

      1. 926.Contributions to expenditure

      2. 927.Contributions not made by public bodies nor eligible for tax relief

      3. 928.Exchanges

      4. 929.Apportionment where property sold together

      5. 930.Questions about apportionments affecting two or more persons

      6. 931.Meaning of “capital sums” etc

  11. Part 9A Company distributions

    1. Chapter 1 The charge to tax

      1. 931A.Charge to tax on distributions received

    2. Chapter 2 Exemption of distributions received by small companies

      1. 931B.Exemption from charge to tax

      2. 931C.Meaning of “qualifying territory”

    3. Chapter 3 Exemption of distributions received by companies that are not small

      1. 931D.Exemption from charge to tax

      2. Exempt classes

        1. 931E.Distributions from controlled companies

        2. 931F.Distributions in respect of non-redeemable ordinary shares

        3. 931G.Distributions in respect of portfolio holdings

        4. 931H.Dividends derived from transactions not designed to reduce tax

        5. 931I.Dividends in respect of shares accounted for as liabilities

      3. Exempt classes: anti-avoidance

        1. 931J.Schemes involving manipulation of controlled company rules

        2. 931K.Schemes involving quasi-preference or quasi-redeemable shares

        3. 931L.Schemes involving manipulation of portfolio holdings rule

        4. 931M.Schemes in the nature of loan relationships

        5. 931N.Schemes involving distributions for which deductions are given

        6. 931O.Schemes involving payments for distributions

        7. 931P.Schemes involving payments not on arm's length terms

        8. 931Q.Schemes involving diversion of trade income

    4. Chapter 4 Supplementary

      1. Election that distribution should not be exempt

        1. 931R.Election that distribution should not be exempt

      2. Interpretation

        1. 931S.Meaning of “small company”

        2. 931T.Meaning of “payer”, “recipient” and “relevant person”

        3. 931U.Meaning of “ordinary share” and “redeemable”

        4. 931V.Meaning of “scheme” and “tax advantage scheme”

      3. Boundary provisions

        1. 931W.Provisions which must be given priority over this Part

  12. Part 10 Miscellaneous income

    1. Chapter 1 Introduction

      1. 932.Overview of Part

    2. Chapter 2 Dividends of non-UK resident companies

      1. 933.Charge to tax on dividends of non-UK resident companies

    3. Chapter 3 Beneficiaries' income from estates in administration

      1. Introduction

        1. 934.Charge to tax on estate income

        2. 935.Absolute, limited and discretionary interests

        3. 936.Meaning of “UK estate” and “foreign estate”

      2. Types of estate income

        1. 937.Absolute interests in residue

        2. 938.Meaning of “the administration period”, “the final accounting period” and “the final tax year”

        3. 939.Limited interests in residue

        4. 940.Discretionary interests in residue

      3. Income charged

        1. 941.UK estates

        2. 942.Foreign estates

      4. Basic amount of estate income: general calculations rules

        1. 943.Absolute interests

        2. 944.Limited interests

        3. 945.Discretionary interests

        4. 946.Applicable rate for grossing up basic amounts of estate income

        5. 947.Aggregate income of the estate

      5. Further provisions for calculating estate income relating to absolute interests

        1. 948.Assumed income entitlement

        2. 949.Residuary income of the estate

        3. 950.Shares of residuary income of estate

        4. 951.Reduction in share of residuary income of estate

        5. 952.Applicable rate for determining assumed income entitlement (UK estates)

      6. Successive interests

        1. 953.Introduction

        2. 954.Successive absolute interests

        3. 955.Assumed income entitlement of holder of absolute interest following limited interest

        4. 956.Payments in respect of limited interests followed by absolute interests

        5. 957.Holders of limited interests

        6. 958.Basic amount of estate income: successive limited interests

        7. 959.Apportionments

      7. Relief where foreign estates have borne UK income tax

        1. 960.Relief in respect of tax relating to absolute interests

        2. 961.Relief in respect of tax relating to limited or discretionary interests

      8. General

        1. 962.Income from which basic amounts are treated as paid

        2. 963.Income treated as bearing income tax

        3. 964.Transfers of assets etc treated as payments

        4. 965.Assessments, adjustments and claims after the administration period

        5. 966.Power to obtain information from personal representatives and beneficiaries

        6. 967.Statements relating to estate income

      9. ...

        1. 968.Meaning of “personal representatives”

    4. Chapter 4 Income from holding an office

      1. 969.Charge to tax on income from holding an office

      2. 970.Rule restricting deductions for bad debts

    5. Chapter 5 Distributions from unauthorised unit trusts

      1. 971.Overview of Chapter

      2. 972.Charge to tax under this Chapter

      3. 973.Amount of income treated as received

    6. Chapter 6 Sale of foreign dividend coupons

      1. 974.Charge to tax under this Chapter

      2. 975.Meaning of “foreign holdings” etc

    7. Chapter 7 Annual payments not otherwise charged

      1. 976.Overview of Chapter

      2. 977.Charge to tax on annual payments not otherwise charged

      3. 978.Exemption for payments by persons liable to pool betting duty

    8. Chapter 8 Income not otherwise charged

      1. 979.Charge to tax on income not otherwise charged

      2. 980.Exemption for commercial occupation of woodlands in UK

      3. 981.Exemption for gains on financial futures

    9. Chapter 9 Priority rules

      1. 982.Provisions which must be given priority over this Part

  13. Part 11 Relief for particular employee share acquisition schemes

    1. Chapter 1 Share incentive plans

      1. Introductory

        1. 983.Overview of Chapter

        2. 984.Chapter to form part of SIP code etc

      2. Deductions and receipts: general

        1. 985.References to a deduction being allowed to a company

        2. 986.Treatment of receipts under Chapter

      3. Deductions relating to setting up and running costs

        1. 987.Deduction for costs of setting up an approved share incentive plan

        2. 988.Deductions for running expenses of an approved share incentive plan

      4. Deductions relating to payments used to acquire shares

        1. 989.Deduction for contribution to plan trust

        2. 990.Withdrawal of deduction under section 989

        3. 991.Another deduction to be allowed if all acquired shares are awarded

        4. 992.Award of shares to excluded employee

        5. 993.Plan termination notice

      5. Deductions relating to provision of certain types of shares

        1. 994.Deduction for providing free or matching shares

        2. 995.Deduction for additional expense in providing partnership shares

        3. 996.Shares excluded from sections 994 and 995

        4. 997.No deduction for expenses in providing dividend shares

      6. Withdrawal of approval for a plan

        1. 998.Withdrawal of deductions if approval for share incentive plan withdrawn

    2. Chapter 2 SAYE option schemes, company share option schemes and employee share options trusts

      1. 999.Deduction for costs of setting up SAYE option scheme or CSOP scheme

      2. 1000.Deduction for costs of setting up employee share ownership trust

  14. Part 12 Other relief for employee share acquisitions

    1. Chapter 1 Introduction

      1. Introductory

        1. 1001.Overview of Part

      2. Interpretation

        1. 1002.“Employment”

        2. 1003.“Shares” etc

        3. 1004.Groups, consortiums and commercial associations of companies

        4. 1005.Other definitions

    2. Chapter 2 Relief if shares acquired by employee or other person

      1. Introductory

        1. 1006.Overview of Chapter

      2. Requirements to be met for relief to be available

        1. 1007.Basic requirements for relief under Chapter 2

        2. 1008.Conditions relating to shares acquired

        3. 1009.Conditions relating to employee's income tax position

      3. Calculation of amount of relief

        1. 1010.Calculation of relief if shares are neither restricted nor convertible

        2. 1011.Calculation of relief if shares are restricted or convertible

        3. 1012.Reduction in amount of relief

      4. Giving of relief

        1. 1013.How the relief is given

    3. Chapter 3 Relief if employee or other person obtains option to acquire shares

      1. Introductory

        1. 1014.Overview of Chapter

      2. Requirements to be met for relief to be available

        1. 1015.Basic requirements for relief under Chapter 3

        2. 1016.Conditions relating to shares acquired

        3. 1017.Condition relating to employee's income tax position

      3. Calculation of amount of relief

        1. 1018.Calculation of relief if shares are neither restricted nor convertible

        2. 1019.Calculation of relief if shares are restricted or convertible

        3. 1020.Reduction in amount of relief

      4. Giving of relief

        1. 1021.How the relief is given

      5. Takeovers and transfers of businesses

        1. 1022.Takeover of company whose shares are subject to option

        2. 1023.Supplementary provision for purposes of section 1022

        3. 1024.Transfer of qualifying business by group transfers

    4. Chapter 4 Additional relief in cases involving restricted shares

      1. 1025.Additional relief available if shares acquired are restricted shares

      2. 1026.Relief available on occurrence of chargeable event

      3. 1027.Relief available on death of employee

      4. 1028.Supplementary provision for purposes of sections 1026 and 1027

      5. 1029.Transfer of qualifying business by group transfers

    5. Chapter 5 Additional relief in cases involving convertible securities

      1. 1030.Application of Chapter

      2. 1031.Additional relief available if shares acquired are convertible shares etc

      3. 1032.Meaning of “chargeable event”

      4. 1033.Relief available on occurrence of chargeable event

      5. 1034.Relief available following death of employee

      6. 1035.Supplementary provision for purposes of sections 1033 and 1034

      7. 1036.Transfer of qualifying business by group transfers

    6. Chapter 6 Relationship between relief under this Part and other reliefs

      1. 1037.Priority of Chapter 1 of Part 11

      2. 1038.Exclusion of other deductions

  15. Part 13 Additional relief for expenditure on research and development

    1. Chapter 1 Introduction

      1. Introductory

        1. 1039.Overview of Part

        2. 1040.Relief may be available under more than one Chapter of Part

      2. Interpretation

        1. 1041.“Research and development”

        2. 1042.“Relevant research and development”

    2. Chapter 2 Relief for SMEs: cost of R&D incurred by SME

      1. Introductory

        1. 1043.Overview of Chapter

      2. Reliefs

        1. 1044.Additional deduction in calculating profits of trade

        2. 1045.Alternative treatment for pre-trading expenditure: deemed trading loss

      3. Reliefs: further provision

        1. 1046.Relief only available where company is going concern

        2. 1047.Elections under section 1045

        3. 1048.Treatment of deemed trading loss under section 1045

        4. 1049.Restriction on consortium relief

      4. Threshold

        1. 1050.R&D threshold

      5. Qualifying expenditure

        1. 1051.Qualifying Chapter 2 expenditure

        2. 1052.Qualifying expenditure on in-house direct R&D

        3. 1053.Qualifying expenditure on contracted out R&D

      6. Tax credit: entitlement and payment

        1. 1054.Entitlement to and payment of tax credit

        2. 1055.Meaning of “Chapter 2 surrenderable loss”

        3. 1056.Amount of trading loss which is “unrelieved”

        4. 1057.Tax credit only available where company is going concern

      7. Amount of tax credit

        1. 1058.Amount of tax credit

        2. 1059.Total amount of company's PAYE and NIC liabilities

      8. Supplementary

        1. 1060.Payment of tax credit

        2. 1061.Tax credit payment not income of company

        3. 1062.Restriction on losses carried forward where tax credit claimed

    3. Chapter 3 Relief for SMEs: R&D sub-contracted to SME

      1. Relief

        1. 1063.Additional deduction in calculating profits of trade

      2. Threshold

        1. 1064.R&D threshold

      3. Qualifying expenditure

        1. 1065.Qualifying Chapter 3 expenditure

        2. 1066.Expenditure on sub-contracted R&D undertaken in-house

        3. 1067.Expenditure on sub-contracted R&D not undertaken in-house

    4. Chapter 4 Relief for SMEs: subsidised and capped expenditure on R&D

      1. Relief

        1. 1068.Additional deduction in calculating profits of trade

      2. Threshold

        1. 1069.R&D threshold

      3. Qualifying expenditure

        1. 1070.Qualifying Chapter 4 expenditure

        2. 1071.Subsidised qualifying expenditure on in-house direct R&D

        3. 1072.Subsidised qualifying expenditure on contracted out R&D

        4. 1073.Capped R&D expenditure

    5. Chapter 5 Relief for large companies

      1. Relief

        1. 1074.Additional deduction in calculating profits of trade

      2. Threshold

        1. 1075.R&D threshold

      3. Qualifying expenditure

        1. 1076.Qualifying Chapter 5 expenditure

        2. 1077.Qualifying expenditure on in-house direct R&D

        3. 1078.Qualifying expenditure on contracted out R&D

        4. 1079.Qualifying expenditure on contributions to independent R&D

      4. Insurance companies

        1. 1080.Entitlement to relief: I minus E basis

    6. Chapter 6 Chapters 2 to 5: further provision

      1. 1081.Insurance companies treated as large companies

      2. 1082.R&D expenditure of group companies

      3. 1083.Refunds of expenditure treated as income chargeable to tax

      4. 1084.Artificially inflated claims for relief or tax credit

    7. Chapter 7 Relief for SMEs and large companies: vaccine research etc

      1. Introductory

        1. 1085.Overview of Chapter

        2. 1086.Meaning of “qualifying R&D activity”

      2. Reliefs

        1. 1087.Deduction in calculating profits of trade

        2. 1088.Large companies: declaration about effect of relief

        3. 1089.SMEs: amount of deduction

        4. 1090.Modification of section 1089 for larger SMEs

        5. 1091.Large companies: amount of deduction

        6. 1092.SMEs: deemed trading loss for pre-trading expenditure

        7. 1093.Modification of section 1092 for larger SMEs

        8. 1094.Relief only available to SME where company is going concern

      3. Deemed trading loss: further provision

        1. 1095.Elections under section 1092

        2. 1096.Treatment of deemed trading loss under section 1092

      4. Threshold

        1. 1097.R&D threshold

      5. Qualifying expenditure

        1. 1098.Meaning of “qualifying Chapter 7 expenditure”

        2. 1099.SMEs: qualifying expenditure “for” an accounting period

        3. 1100.Large companies: qualifying expenditure “for” an accounting period

        4. 1101.Qualifying expenditure on in-house direct R&D

        5. 1102.Qualifying expenditure on contracted out R&D

      6. Tax credit: entitlement and payment

        1. 1103.Entitlement to and payment of tax credit

        2. 1104.Meaning of “Chapter 7 surrenderable loss”

        3. 1105.Amount of trading loss which is “unrelieved”

        4. 1106.Tax credit only available where company is going concern

      7. Amount of tax credit

        1. 1107.Amount of tax credit

        2. 1108.Total amount of company's PAYE and NIC liabilities

      8. Supplementary

        1. 1109.Payment of tax credit

        2. 1110.Tax credit payment not income of company

        3. 1111.Restriction on losses carried forward where tax credit claimed

      9. Tax avoidance

        1. 1112.Artificially inflated claims for relief or tax credit

    8. Chapter 8 Cap on aid for R&D

      1. 1113.Cap on R&D aid under Chapter 2 or 7

      2. 1114.Total R&D aid

      3. 1115.“The tax credits”

      4. 1116.“The actual reduction in tax liability”

      5. 1117.“The potential relief”

      6. 1118.“The notional relief”

    9. Chapter 9 Supplementary

      1. SMEs and large companies

        1. 1119.“Small or medium-sized enterprise”

        2. 1120.Qualifications to section 1119

        3. 1121.“Larger SME”

        4. 1122.“Large company”

      2. Staffing costs

        1. 1123.“Staffing costs”

        2. 1124.Staffing costs: attributable expenditure

      3. Software or consumable items

        1. 1125.“Software or consumable items”

        2. 1126.Software or consumable items: attributable expenditure

      4. Qualifying expenditure on externally provided workers

        1. 1127.“Qualifying expenditure on externally provided workers”

        2. 1128.“Externally provided worker”

        3. 1129.Qualifying expenditure on externally provided workers: connected persons

        4. 1130.Election for connected persons treatment

        5. 1131.Qualifying expenditure on externally provided workers: other cases

        6. 1132.External workers: attributable expenditure

      5. Sub-contractor payments

        1. 1133.“Sub-contractor” and “sub-contractor payment”

        2. 1134.Qualifying element of sub-contractor payment: connected persons

        3. 1135.Election for connected persons treatment

        4. 1136.Qualifying element of sub-contractor payment: other cases

      6. Miscellaneous

        1. 1137.Accounting periods: company not within charge to corporation tax

        2. 1138.“Subsidised expenditure”

        3. 1139.“Intellectual property”

        4. 1140.“Relevant payments to the subjects of a clinical trial”

        5. 1141.“Payment period”

        6. 1142.“Qualifying body”

  16. Part 14 Remediation of contaminated or derelict land

    1. Chapter 1 Introduction

      1. Introductory

        1. 1143.Overview of Part

      2. Basic definitions

        1. 1144.“Qualifying land remediation expenditure”

        2. 1145.Land “in a contaminated state”

        3. 1145A.Land “in a derelict state”

        4. 1145B.Exclusion of nuclear sites

        5. 1146.“Relevant contaminated land remediation”

        6. 1146A.“Relevant derelict land remediation”

    2. Chapter 2 Reliefs for expenditure on contaminated or derelict land

      1. 1147.Deduction for capital expenditure

      2. 1148.Election under section 1147

      3. 1149.Additional deduction for qualifying land remediation expenditure

      4. 1150.No relief if company responsible for contamination or dereliction or polluter has interest

    3. Chapter 3 Land remediation tax credit

      1. Entitlement and payment

        1. 1151.Entitlement to and payment of tax credit

        2. 1152.Meaning of “qualifying land remediation loss”

        3. 1153.Amount of a loss which is “unrelieved”

      2. Amount of tax credit

        1. 1154.Amount of tax credit

      3. Supplementary

        1. 1155.Payment of tax credit

        2. 1156.Tax credit payment not income of company

        3. 1157.Exclusion for capital gains purposes of certain expenditure

        4. 1158.Restriction on losses carried forward where tax credit claimed

    4. Chapter 4 Special provision for life assurance business

      1. General

        1. 1159.Limitation on relief under Chapter 2

      2. I minus E basis

        1. 1160.Provision in respect of I minus E basis

      3. Relief for qualifying Chapter 4 expenditure

        1. 1161.Relief in respect of I minus E basis: ... expenses payable

        2. 1162.Additional relief

        3. 1163.No relief if company responsible for contamination or dereliction or polluter has interest

      4. Life assurance company tax credits

        1. 1164.Entitlement to tax credit

        2. 1165.Meaning of “qualifying life assurance business loss”

        3. 1166.Amount of tax credit

        4. 1167.Payment of tax credit etc

        5. 1168.Restriction on carrying forward expenses payable where tax credit claimed

    5. Chapter 5 Tax avoidance

      1. 1169.Artificially inflated claims for relief or tax credit

    6. Chapter 6 Supplementary

      1. 1170.“Staffing costs”

      2. 1171.Staffing costs attributable to relevant land remediation

      3. 1172.Expenditure on materials

      4. 1173.Expenditure incurred because of contamination or dereliction

      5. 1174.Sub-contractor payments

      6. 1175.Connected sub-contractors

      7. 1176.“Qualifying expenditure on sub-contracted land remediation”: other cases

      8. 1177.“Subsidised expenditure”

      9. 1178.Persons having a “relevant connection” to a company

      10. 1178A.“Major interest in land”

      11. 1179.Other definitions

  17. Part 15 Film production

    1. Chapter 1 Introduction

      1. Introductory

        1. 1180.Overview of Part

      2. Interpretation

        1. 1181.“Film” etc

        2. 1182.“Film production company”

        3. 1183.“Film-making activities” etc

        4. 1184.“Production expenditure”, “core expenditure” and “limited-budget film”

        5. 1185.“UK expenditure” etc

        6. 1186.“Qualifying co-production” and “co-producer”

        7. 1187.“Company tax return”

    2. Chapter 2 Taxation of activities of film production company

      1. Separate film trade

        1. 1188.Activities of film production company treated as a separate trade

        2. 1189.Calculation of profits or losses of separate film trade

      2. Supplementary

        1. 1190.Income from the film

        2. 1191.Costs of the film

        3. 1192.When costs are taken to be incurred

        4. 1193.Pre-trading expenditure

        5. 1194.Estimates

    3. Chapter 3 Film tax relief

      1. Introductory

        1. 1195.Availability and overview of film tax relief

      2. Conditions of relief

        1. 1196.Intended theatrical release

        2. 1197.British film

        3. 1198.UK expenditure

      3. Additional deductions

        1. 1199.Additional deduction for qualifying expenditure

        2. 1200.Amount of additional deduction

      4. Film tax credits

        1. 1201.Film tax credit claimable if company has surrenderable loss

        2. 1202.Surrendering of loss and amount of film tax credit

        3. 1203.Payment in respect of film tax credit

      5. Miscellaneous

        1. 1204.No account to be taken of amount if unpaid

        2. 1205.Artificially inflated claims for additional deduction or film tax credit

        3. 1206.Confidentiality of information

        4. 1207.Wrongful disclosure

    4. Chapter 4 Film losses

      1. 1208.Application of sections 1209 and 1210

      2. 1209.Restriction on use of losses while film in production

      3. 1210.Use of losses in later periods

      4. 1211.Terminal losses

    5. Chapter 5 Provisional entitlement to relief

      1. 1212.Introduction

      2. 1213.Certification as a British film

      3. 1214.The UK expenditure condition

      4. 1215.Film tax relief on basis that film is limited-budget film

      5. 1216.Time limit for amendments and assessments

  18. Part 16 Companies with investment business

    1. Chapter 1 Introduction

      1. 1217.Overview of Part

      2. 1218.“Company with investment business” and “investment business”

    2. Chapter 2 Management expenses

      1. Relief for expenses of management

        1. 1219.Expenses of management of a company's investment business

        2. 1220.Meaning of “unallowable purpose”

        3. 1221.Amounts treated as expenses of management

        4. 1222.Income from a source not charged to tax

        5. 1223.Carrying forward expenses of management and other amounts

      2. Accounting period to which expenses are referable

        1. 1224.Accounting period to which expenses are referable

        2. 1225.Accounts conforming with GAAP

        3. 1226.Accounts not conforming with GAAP

        4. 1227.Accounts not drawn up

      3. Claw back of relief

        1. 1228.Credits that reverse debits

        2. 1229.Claw back of relief

        3. 1230.Meaning of “reversal amount”

        4. 1231.Absence of accounts

    3. Chapter 3 Amounts treated as expenses of management

      1. Preliminary

        1. 1232.Chapter applies to amounts not otherwise relieved

      2. Excess capital allowances

        1. 1233.Excess capital allowances

      3. Payments for restrictive undertakings

        1. 1234.Payments for restrictive undertakings

      4. Seconded employees

        1. 1235.Employees seconded to charities and educational establishments

      5. Contributions to agents' expenses

        1. 1236.Payroll deduction schemes

      6. Counselling and retraining expenses

        1. 1237.Counselling and other outplacement services

        2. 1238.Retraining courses

      7. Redundancy payments etc

        1. 1239.Redundancy payments and approved contractual payments

        2. 1240.Payments in respect of employment wholly in employer's business

        3. 1241.Payments in respect of employment in more than one capacity

        4. 1242.Additional payments

        5. 1243.Payments made by the Government

      8. Contributions to local enterprise organisations or urban regeneration companies

        1. 1244.Contributions to local enterprise organisations or urban regeneration companies

      9. Export Credits Guarantee Department

        1. 1245.Payments to Export Credits Guarantee Department

      10. Levies under FISMA 2000

        1. 1246.Levies under FISMA 2000

    4. Chapter 4 Rules restricting deductions

      1. 1247.Introduction

      2. 1248.Expenses in connection with arrangements for securing a tax advantage

      3. 1249.Unpaid remuneration

      4. 1250.Unpaid remuneration: supplementary

      5. 1251.Car or motor cycle hire

    5. Chapter 5 Companies with investment business: receipts

      1. 1252.Industrial development grants

      2. 1253.Contributions to local enterprise organisations or urban regeneration companies: disqualifying benefits

      3. 1254.Repayments under FISMA 2000

    6. Chapter 6 Supplementary

      1. 1255.Meaning of some accounting terms

  19. Part 17 Partnerships

    1. Introduction

      1. 1256.Overview of Part

      2. 1257.General provisions

      3. 1258.Assessment of firms

    2. Calculation of partners' shares

      1. 1259.Calculation of firm's profits and losses

      2. 1260.Section 1259: supplementary

      3. 1261.Accounting periods of firms

      4. 1262.Allocation of firm's profits or losses between partners

      5. 1263.Profit-making period in which some partners have losses

      6. 1264.Loss-making period in which some partners have profits

      7. 1265.Apportionment of profit share between partner's accounting periods

    3. Firms with a foreign element

      1. 1266.Resident partners and double taxation agreements

    4. Adjustment on change of basis

      1. 1267.Various rules for trades and property businesses

      2. 1268.Election for spreading under Chapter 14 of Part 3

      3. 1269.Interpretation of sections 1267 and 1268

    5. Miscellaneous

      1. 1270.Special provisions about farming and property income

      2. 1271.Sale of patent rights: effect of partnership changes

      3. 1272.Sale of patent rights: effect of later cessation of trade

      4. 1273.Limited liability partnerships

  20. Part 18 Unremittable income

    1. 1274.Unremittable income: introduction

    2. 1275.Claim for relief for unremittable income

    3. 1276.Withdrawal of relief

    4. 1277.Income charged on withdrawal of relief after source ceases

    5. 1278.Valuing unremittable income

  21. Part 19 General exemptions

    1. Profits from FOTRA securities

      1. 1279.Exemption of profits from securities free of tax to residents abroad (“FOTRA securities”)

      2. 1280.Section 1279: supplementary provision

    2. Income from savings certificates

      1. 1281.Income from savings certificates

      2. 1282.Income from Ulster Savings Certificates

    3. Miscellaneous

      1. 1283.Interest from tax reserve certificates

      2. 1284.Housing grants

      3. 1285.UK company distributions

      4. 1286.VAT repayment supplements

      5. 1287.Incentives to use electronic communications

  22. Part 20 General calculation rules

    1. Chapter 1 Restriction of deductions

      1. Unpaid remuneration

        1. 1288.Unpaid remuneration

        2. 1289.Unpaid remuneration: supplementary

      2. Employee benefit contributions

        1. 1290.Employee benefit contributions

        2. 1291.Making of “employee benefit contributions”

        3. 1292.Provision of qualifying benefits

        4. 1293.Timing and amount of certain qualifying benefits

        5. 1294.Provision or payment out of employee benefit contributions

        6. 1295.Profits calculated before end of 9 month period

        7. 1296.Interpretation of sections 1290 to 1296

        8. 1297.Life assurance business

      3. Business entertainment and gifts

        1. 1298.Business entertainment and gifts

        2. 1299.Business entertainment: exceptions

        3. 1300.Business gifts: exceptions

      4. Miscellaneous

        1. 1301.Restriction of deductions for annual payments

        2. 1301A.Restriction of deductions for interest

        3. 1301B.Qualifying charitable donations

        4. 1302.Social security contributions

        5. 1303.Penalties, interest and VAT surcharges

        6. 1304.Crime-related payments

        7. 1305.Dividends and other distributions

    2. Chapter 2 Other general rules

      1. Miscellaneous profits and losses

        1. 1306.Losses calculated on same basis as miscellaneous income

        2. 1307.Apportionment etc of miscellaneous profits and losses to accounting period

      2. Expenditure on research and development

        1. 1308.Expenditure brought into account in determining value of intangible asset

      3. Visiting performers

        1. 1309.Payments treated as made to visiting performers

  23. Part 21 Other general provisions

    1. Orders and regulations

      1. 1310.Orders and regulations

    2. ...

      1. 1311.Apportionment to different periods

    3. Interpretation

      1. 1312.Abbreviated references to Acts

      2. 1313.Activities in UK sector of continental shelf

      3. 1314.Meaning of “caravan”

      4. 1315.Claims and elections

      5. 1316.Meaning of “connected” persons and “control”

      6. 1317.Meaning of “farming” and related expressions

      7. 1318.Meaning of grossing up

      8. 1319.Other definitions

      9. 1320.Interpretation: Scotland

      10. 1321.Interpretation: Northern Ireland

    4. Final provisions

      1. 1322.Minor and consequential amendments

      2. 1323.Power to make consequential provision

      3. 1324.Power to undo changes

      4. 1325.Transitional provisions and savings

      5. 1326.Repeals and revocations

      6. 1327.Index of defined expressions

      7. 1328.Extent

      8. 1329.Commencement

      9. 1330.Short title

  24. SCHEDULES

    1. SCHEDULE 1

      Minor and consequential amendments

      1. Part 1 Income and Corporation Taxes Act 1988

        1. 1.The Income and Corporation Taxes Act 1988 (c. 1) is...

        2. 2.(1) Amend section 6 (the charge to corporation tax and...

        3. 3.Omit section 8 (general scheme of corporation tax).

        4. 4.(1) Amend section 9 (computation of income: application of income...

        5. 5.In section 11 (companies not resident in United Kingdom) omit...

        6. 6.Omit section 11AA (determination of profits attributable to permanent establishment)....

        7. 7.Omit section 12(1) to (7ZA) and (9) (basis of, and...

        8. 8.Omit section 15 (Schedule A).

        9. 9.Omit section 18 (Schedule D).

        10. 10.Omit section 21A (computation of amount chargeable under Schedule A)....

        11. 11.Omit section 21B (application of other rules applicable to Case...

        12. 12.Omit section 21C (the Schedule A charge and mutual business)....

        13. 13.(1) Amend section 24 (construction of Part 2) as follows....

        14. 14.Omit section 30 (expenditure on making sea walls).

        15. 15.Omit sections 31ZA to 31ZC (deductions for expenditure on energy-saving...

        16. 16.Omit sections 34 to 39 (premiums, leases at undervalue etc)....

        17. 17.Omit section 40 (tax treatment of receipts and outgoings on...

        18. 18.(1) Amend section 42 (appeals against determinations under sections 34...

        19. 19.Omit section 46 (savings certificates and tax reserve certificates).

        20. 20.Omit section 53 (farming and other commercial occupation of land...

        21. 21.Omit section 55 (mines, quarries and other concerns).

        22. 22.(1) Amend section 56 (transactions in deposits with and without...

        23. 23.Omit section 70 (basis of assessment etc).

        24. 24.Omit section 70A (Case V income from land outside UK)....

        25. 25.Omit section 72 (apportionments etc for purposes of Cases I,...

        26. 26.Omit section 74 (general rules as to deductions not allowable)....

        27. 27.Omit section 75 (expenses of management: companies with investment business)....

        28. 28.Omit section 75A (accounting period to which expenses of management...

        29. 29.Omit section 75B (amounts reversing expenses of management deducted: charge...

        30. 30.(1) Amend section 76 (expenses of insurance companies) as follows....

        31. 31.After section 76 insert— Payments for restrictive undertakings Payments for...

        32. 32.After section 76ZA insert— Seconded employees Employees seconded to charities...

        33. 33.After section 76ZB insert— Counselling and retraining expenses Counselling and...

        34. 34.After section 76ZC insert— Retraining courses (1) This section applies if— (a) a company carrying on...

        35. 35.After section 76ZD insert— Retraining courses: recovery of tax (1) This section applies if— (a) an employer's liability to...

        36. 36.After section 76ZE insert— Redundancy payments etc Redundancy payments and...

        37. 37.After section 76ZF insert— Payments in respect of employment wholly...

        38. 38.After section 76ZG insert— Payments in respect of employment in...

        39. 39.After section 76ZH insert— Additional payments (1) This section applies if the employer's business, or part...

        40. 40.After section 76ZI insert— Payments by the Government (1) This section applies if— (a) a redundancy payment or...

        41. 41.After section 76ZJ insert— Contributions to local enterprise organisations or...

        42. 42.After section 76ZK insert— Unpaid remuneration Unpaid remuneration (1) This section applies if— (a) an amount is charged...

        43. 43.After section 76ZL insert— Unpaid remuneration: supplementary (1) For the purposes of section 76ZL an amount charged...

        44. 44.After section 76ZM insert— Car or motor cycle hire Car...

        45. 45.Income and Corporation Taxes Act 1988

        46. 46.Omit section 76A (levies and repayments under FISMA 2000).

        47. 47.Omit section 76B (levies and repayments under the FISMA 2000:...

        48. 48.Omit section 79 (contributions to local enterprise agencies).

        49. 49.Omit section 79A (contributions to training and enterprise councils and...

        50. 50.Omit section 79B (contributions to urban regeneration companies).

        51. 51.Omit section 82A (expenditure on research and development).

        52. 52.Omit section 82B (payments to research associations, universities etc).

        53. 53.Omit section 83 (patent fees etc and expenses).

        54. 54.Omit section 83A (gifts in kind to charities etc).

        55. 55.Omit section 84 (gifts to educational establishments).

        56. 56.(1) Amend section 84A (costs of establishing share option or...

        57. 57.Omit section 85 (payments to trustees of approved profit sharing...

        58. 58.Omit section 85A (costs of establishing employee share ownership trust:...

        59. 59.Omit section 85B (which introduces Schedule 4AA).

        60. 60.Omit section 86 (employees seconded to charities and educational establishments)....

        61. 61.Omit section 86A (charitable donations: contributions to agent's expenses).

        62. 62.Omit sections 87 and 87A (taxable premiums etc).

        63. 63.Omit section 88 (payments to Export Credits Guarantee Department).

        64. 64.Omit section 88D (restriction of deductions in respect of certain...

        65. 65.Omit section 89 (debts proving to be irrecoverable after discontinuance...

        66. 66.Omit section 90 (additional payments to redundant employees).

        67. 67.Omit section 91 (cemeteries).

        68. 68.Omit section 91A (waste disposal: restoration payments).

        69. 69.Omit sections 91B and 91BA (waste disposal: preparation expenditure).

        70. 70.Omit section 91C (mineral exploration and access).

        71. 71.Omit section 92 (regional development grants).

        72. 72.Omit section 93 (other grants under Industrial Development Act 1982...

        73. 73.Omit section 94 (debts deducted and subsequently released).

        74. 74.Omit section 95 (taxation of dealers in respect of distributions...

        75. 75.In section 95ZA(1) (taxation of UK distributions received by insurance...

        76. 76.Omit section 97 (treatment of farm animals etc).

        77. 77.Omit section 98 (tied premises: receipts and expenses treated as...

        78. 78.Omit section 99 (dealers in land).

        79. 79.Omit section 100 (valuation of trading stock at discontinuance of...

        80. 80.Omit section 101 (valuation of work in progress at discontinuance...

        81. 81.Omit section 102 (provisions supplementary to sections 100 and 101)....

        82. 82.Omit sections 103 to 106 (Case VI charges on receipts)....

        83. 83.Omit section 110 (interpretation etc).

        84. 84.Omit section 111(1) (treatment of partnerships).

        85. 85.Omit sections 114 and 115 (special rules for computing profits...

        86. 86.Income and Corporation Taxes Act 1988

        87. 87.Omit section 118ZA (treatment of limited liability partnerships).

        88. 88.Omit section 119 (rent etc payable in connection with mines,...

        89. 89.Omit section 120 (rent etc payable in respect of electric...

        90. 90.Omit section 121 (management expenses of owner of mineral rights)....

        91. 91.Omit section 122 (relief in respect of mineral royalties).

        92. 92.Omit section 125 (annual payments for dividends or non-taxable consideration)....

        93. 93.Omit section 128(2) and (3) (commodity and financial futures etc:...

        94. 94.(1) Amend section 130 (meaning of “company with investment business”...

        95. 95.In section 187(10) (interpretation of sections 185 and 186) for...

        96. 96.Omit section 208 (UK company distributions not generally chargeable to...

        97. 97.Income and Corporation Taxes Act 1988

        98. 98.Income and Corporation Taxes Act 1988

        99. 99.Income and Corporation Taxes Act 1988

        100. 100.Income and Corporation Taxes Act 1988

        101. 101.Income and Corporation Taxes Act 1988

        102. 102.Income and Corporation Taxes Act 1988

        103. 103.Omit section 337 (company beginning or ceasing to carry on...

        104. 104.(1) Amend section 337A (computation of company's profits or income:...

        105. 105.Income and Corporation Taxes Act 1988

        106. 106.Income and Corporation Taxes Act 1988

        107. 107.Income and Corporation Taxes Act 1988

        108. 108.Income and Corporation Taxes Act 1988

        109. 109.Income and Corporation Taxes Act 1988

        110. 110.Income and Corporation Taxes Act 1988

        111. 111.Income and Corporation Taxes Act 1988

        112. 112.Income and Corporation Taxes Act 1988

        113. 113.Income and Corporation Taxes Act 1988

        114. 114.In section 398(b) for “Schedule D” substitute “ Part 5...

        115. 115.Income and Corporation Taxes Act 1988

        116. 116.Income and Corporation Taxes Act 1988

        117. 117.Omit section 401 (relief for pre-trading expenditure).

        118. 118.Income and Corporation Taxes Act 1988

        119. 119.Income and Corporation Taxes Act 1988

        120. 120.Income and Corporation Taxes Act 1988

        121. 121.Income and Corporation Taxes Act 1988

        122. 122.Income and Corporation Taxes Act 1988

        123. 123.Income and Corporation Taxes Act 1988

        124. 124.Income and Corporation Taxes Act 1988

        125. 125.In section 414(1)(b) (close companies) omit “within the meaning of...

        126. 126.(1) Amend section 431 (interpretation of provisions relating to insurance...

        127. 127.(1) Amend section 431G (company carrying on life assurance business)...

        128. 128.In section 431H(3) (company carrying on life assurance business and...

        129. 129.(1) Amend section 432YA (long-term business other than life assurance...

        130. 130.(1) Amend section 432A (apportionment of income and gains) as...

        131. 131.(1) Amend section 432AA (Schedule A business or overseas property...

        132. 132.(1) Amend section 432AB (losses from Schedule A business or...

        133. 133.In section 434(1) (franked investment income etc) for “provisions applicable...

        134. 134.(1) Amend section 434A (computation of losses and limitation of...

        135. 135.(1) Amend section 436A (gross roll-up business: separate charge on...

        136. 136.In section 440(6) (transfers of assets etc) for “in accordance...

        137. 137.In section 440A(7) (securities) for “in accordance with Case I...

        138. 138.(1) Amend section 440B (modifications where tax charged under Case...

        139. 139.(1) Amend section 440C (modifications for change of tax basis)...

        140. 140.In section 442(2) (overseas business of UK companies) for “of...

        141. 141.In section 442A(1) (taxation of investment return where risk reinsured)...

        142. 142.(1) Amend section 444AZA (transfers of life assurance business: Case...

        143. 143.(1) Amend section 444AZB (transfers of life assurance business: Case...

        144. 144.In section 444ABD(1A) (transferor's period of account including transfer)—

        145. 145.(1) Amend section 444AEA (transfer schemes: anti-avoidance rule) as follows....

        146. 146.(1) Amend section 444AEB (Case I advantage: transferor) as follows....

        147. 147.(1) Amend section 444AEC (Case I advantage: transferee) as follows....

        148. 148.(1) Amend section 444AECA (parts of transfer scheme arrangements: anti-avoidance...

        149. 149.(1) Amend section 444AECB (parts of transfer scheme arrangements: Case...

        150. 150.(1) Amend section 444AECC (parts of transfer scheme arrangements: Case...

        151. 151.(1) Amend section 444AED (clearance: no avoidance or group advantage)...

        152. 152.In section 444AF(5) (demutualisation surplus: life assurance business)—

        153. 153.In section 444AH (modification of section 444AG etc for Case...

        154. 154.In section 444AK(3) (mutual surplus: gross roll-up business) for “provisions...

        155. 155.In section 444BA(1) (equalisation reserves for general business) for “Case...

        156. 156.In section 444BB(2) (modification of section 444BA for mutual or...

        157. 157.Omit section 469(4A) to (5) and (6) (other unit trusts)....

        158. 158.Omit section 472A (trading profits etc from securities: taxation of...

        159. 159.Omit section 473 (conversion etc of securities held as circulating...

        160. 160.In section 475 (tax-free Treasury securities: exclusion of interest on...

        161. 161.In section 477A (building societies: loan relationships), omit subsections (3)(a)...

        162. 162.Omit section 477B (incidental costs of issuing qualifying shares).

        163. 163.(1) Amend section 486 (industrial and provident societies and co-operative...

        164. 164.Omit section 487 (credit unions).

        165. 165.Omit section 491 (distribution of assets of body corporate carrying...

        166. 166.Income and Corporation Taxes Act 1988

        167. 167.Income and Corporation Taxes Act 1988

        168. 168.Income and Corporation Taxes Act 1988

        169. 169.Income and Corporation Taxes Act 1988

        170. 170.Income and Corporation Taxes Act 1988

        171. 171.Income and Corporation Taxes Act 1988

        172. 172.In section 503(1)(a) (letting of furnished holiday accommodation treated as...

        173. 173.Omit section 504 (meaning of “commercial letting of furnished holiday...

        174. 174.Income and Corporation Taxes Act 1988

        175. 175.Income and Corporation Taxes Act 1988

        176. 176.Omit section 509 (reserves of marketing boards etc).

        177. 177.Income and Corporation Taxes Act 1988

        178. 178.For section 518(2) (harbour reorganisation schemes) substitute—

        179. 179.Omit section 524 (taxation of receipts from sale of patent...

        180. 180.Omit section 525 (capital sums: winding up or partnership change)....

        181. 181.Omit section 526 (relief for expenses).

        182. 182.Omit section 528 (manner of making allowances and charges).

        183. 183.Omit section 531 (provisions supplementary to section 530).

        184. 184.Omit section 532 (application of Capital Allowances Act).

        185. 185.Omit section 533 (interpretation of sections 520 to 532).

        186. 186.Omit section 556 (activity treated as trade etc and attribution...

        187. 187.Omit section 558(5) and (6) (visiting performers: supplementary provisions).

        188. 188.In section 568(1) (deductions from profits of contributions paid under...

        189. 189.In section 570(4) (payments under certified schemes which are not...

        190. 190.(1) Amend section 571 (cancellation of certificates) as follows.

        191. 191.Omit section 577 (business entertaining expenses).

        192. 192.Omit section 577A (expenditure involving crime).

        193. 193.Omit section 578 (housing grants).

        194. 194.Omit sections 578A and 578B (expenditure on car hire).

        195. 195.Omit sections 579 and 580 (statutory redundancy payments).

        196. 196.Omit section 582 (funding bonds issued in respect of interest...

        197. 197.Omit section 584 (relief for unremittable overseas income).

        198. 198.Omit sections 586 and 587 (disallowance of deductions for war...

        199. 199.In section 587B(2)(b) (gifts of shares, securities and real property...

        200. 200.Omit section 588 (training courses for employees).

        201. 201.Omit section 589A (counselling services for employees).

        202. 202.Omit section 589B(5) (interpretation of section 589A).

        203. 203.Omit section 617 (social security benefits and contributions).

        204. 204.Omit section 695 (limited interests in residue).

        205. 205.Omit section 696 (absolute interests in residue).

        206. 206.Omit section 697 (supplementary provisions as to absolute interests in...

        207. 207.Omit section 698 (special provisions as to certain interests in...

        208. 208.Omit section 699A (untaxed sums comprised in the income of...

        209. 209.In section 700 (adjustments and information)— (a) omit subsections (1)...

        210. 210.Omit section 701 (interpretation).

        211. 211.Omit section 702 (application to Scotland).

        212. 212.In section 703(3) (cancellation of corporation tax advantage) omit the...

        213. 213.In section 709(2) (meaning of “corporation tax advantage” and other...

        214. 214.Income and Corporation Taxes Act 1988

        215. 215.Income and Corporation Taxes Act 1988

        216. 216.In section 736C(9) (deemed interest: cash collateral under stock lending...

        217. 217.In section 747(1B) (controlled foreign companies: company residence for purposes...

        218. 218.In section 751(3) (controlled foreign companies: accounting periods) for “subsections...

        219. 219.(1) Amend section 755A (treatment of chargeable profits and creditable...

        220. 220.(1) Amend section 761 (charge to income tax or corporation...

        221. 221.Income and Corporation Taxes Act 1988

        222. 222.Income and Corporation Taxes Act 1988

        223. 223.Income and Corporation Taxes Act 1988

        224. 224.Income and Corporation Taxes Act 1988

        225. 225.In section 774(1) (transactions between dealing company and associated company)...

        226. 226.Income and Corporation Taxes Act 1988

        227. 227.Income and Corporation Taxes Act 1988

        228. 228.Income and Corporation Taxes Act 1988

        229. 229.Income and Corporation Taxes Act 1988

        230. 230.Income and Corporation Taxes Act 1988

        231. 231.(1) Amend section 776 (transactions in land: taxation of capital...

        232. 232.(1) Amend section 779 (sale and lease-back: limitation on tax...

        233. 233.In section 780(3A) (sale and lease-back: taxation of consideration received)...

        234. 234.(1) Amend section 781 (assets leased to traders and others)...

        235. 235.In section 782(9) (leased assets: special cases) omit the words...

        236. 236.In section 785 (definitions for purposes of sections 781 to...

        237. 237.In section 785ZA(3) (restrictions on use of losses: leasing partnerships)...

        238. 238.In section 785ZB(8) (section 785ZA: definitions)— (a) in paragraph (a)...

        239. 239.In section 785C(4)(a) (section 785B: interpretation) for “under Schedule A”...

        240. 240.In section 785D(3) (section 785B: lease of plant and machinery...

        241. 241.(1) Amend section 786 (transactions associated with loans or credit)...

        242. 242.(1) Amend section 787 (restriction of relief for payments of...

        243. 243.In section 788(7) (relief by agreement with other territories) omit...

        244. 244.In section 790(11) (unilateral relief) omit the words from “,...

        245. 245.In section 795(4) (computation of income subject to foreign tax)—...

        246. 246.(1) Amend section 797 (limits on credit: corporation tax) as...

        247. 247.(1) Amend section 797A (foreign tax on items giving rise...

        248. 248.Income and Corporation Taxes Act 1988

        249. 249.Income and Corporation Taxes Act 1988

        250. 250.Income and Corporation Taxes Act 1988

        251. 251.Income and Corporation Taxes Act 1988

        252. 252.Income and Corporation Taxes Act 1988

        253. 253.Income and Corporation Taxes Act 1988

        254. 254.Income and Corporation Taxes Act 1988

        255. 255.Income and Corporation Taxes Act 1988

        256. 256.Income and Corporation Taxes Act 1988

        257. 257.Income and Corporation Taxes Act 1988

        258. 258.Income and Corporation Taxes Act 1988

        259. 259.Income and Corporation Taxes Act 1988

        260. 260.Income and Corporation Taxes Act 1988

        261. 261.Income and Corporation Taxes Act 1988

        262. 262.Income and Corporation Taxes Act 1988

        263. 263.Income and Corporation Taxes Act 1988

        264. 264.Income and Corporation Taxes Act 1988

        265. 265.Omit section 817 (deductions not to be allowed in computing...

        266. 266.In section 821(1)(a) (under-deductions from payments made before passing of...

        267. 267.(1) Amend section 826 (interest on tax overpaid) as follows....

        268. 268.Omit section 827 (VAT penalties etc).

        269. 269.(1) Amend section 828 (orders and regulations made by the...

        270. 270.Omit section 830(2) to (4) (territorial sea and designated areas)....

        271. 271.In section 831(3) (interpretation of ICTA) before the definition of...

        272. 272.Income and Corporation Taxes Act 1988

        273. 273.Income and Corporation Taxes Act 1988

        274. 274.Income and Corporation Taxes Act 1988

        275. 275.Income and Corporation Taxes Act 1988

        276. 276.Income and Corporation Taxes Act 1988

        277. 277.Income and Corporation Taxes Act 1988

        278. 278.Omit Schedule A1 (determination of profits attributable to permanent establishment:...

        279. 279.Omit Schedule 4AA (share incentive plans: corporation tax deductions).

        280. 280.Omit Schedule 5 (treatment of farm animals etc for purposes...

        281. 281.In paragraph 13(3) of Schedule 18A (group relief: overseas losses...

        282. 282.(1) Amend Schedule 19ABA (modification of life assurance provisions of...

        283. 283.In paragraph 6(6)(b) of Schedule 19B (petroleum extraction activities: exploration...

        284. 284.(1) Amend Schedule 19C (petroleum extraction activities: ring fence expenditure...

        285. 285.(1) Amend Schedule 23A (manufactured dividends and interest) as follows....

        286. 286.(1) Amend Schedule 24 (assumptions for calculating chargeable profits, creditable...

        287. 287.(1) Amend Schedule 25 (cases where section 747(3) does not...

        288. 288.In Schedule 26 (reliefs against liability for tax in respect...

        289. 289.(1) Amend Schedule 27 (distributing funds) as follows.

        290. 290.(1) Amend Schedule 28A (change in ownership of company with...

        291. 291.(1) Amend Schedule 28AA (provision not at arm's length) as...

        292. 292.(1) Amend Schedule 30 (transitional provisions and savings) as follows....

      2. Part 2 Other enactments

        1. Finance Act 1950 (c. 15)

          1. 293.The Finance Act 1950 is amended as follows.

          2. 294.In section 39(3) (treatment for taxation purposes of enemy debts...

        2. Taxes Management Act 1970 (c. 9)

          1. 295.The Taxes Management Act 1970 is amended as follows.

          2. 296.In section 12(5) (information about chargeable gains) for “section 100(2)...

          3. 297.Omit section 12AE (choice between different Cases of Schedule D)....

          4. 298.In section 17 (interest paid or credited by banks, building...

          5. 299.In section 18 (interest paid without deduction of income tax)...

          6. 300.(1) Amend section 19 (information for purposes of charge on...

          7. 301.Omit section 31(3) (appeals: right of appeal).

          8. 302.In section 42(7) (procedure for making claims etc)—

          9. 303.In section 46B(5) (questions to be determined by Special Commissioners),...

          10. 304.In section 71(1) (bodies of persons) omit the words from...

          11. 305.In section 87A(4A)(b) (interest on overdue corporation tax etc) for...

          12. 306.(1) Amend section 90 (disallowance of relief for interest on...

          13. 307.(1) Amend section 98 (special returns, etc) as follows.

          14. 308.After section 109 insert— Residence of companies Chapter 3 of Part 2 of CTA 2009 (rules for...

          15. 309.In section 118 (interpretation) at the appropriate place insert— “CTA...

          16. 310.In Schedule 3 (rules for assigning proceedings to General Commissioners),...

        3. Finance Act 1973 (c. 51)

          1. 311.The Finance Act 1973 is amended as follows.

          2. 312.In paragraph 2(a) of Schedule 15 (territorial extension of charge...

        4. Oil Taxation Act 1975 (c. 22)

          1. 313.The Oil Taxation Act 1975 is amended as follows.

          2. 314.In section 3(2) (allowance of expenditure (other than expenditure on...

        5. Inheritance Tax Act 1984 (c. 51)

          1. 315.The Inheritance Tax Act 1984 is amended as follows.

          2. 316.(1) Amend section 91 (administration period) as follows.

          3. 317.In section 94(2)(a) (charge on participators) for “section 208 of...

        6. Films Act 1985 (c. 21)

          1. 318.The Films Act 1985 is amended as follows.

          2. 319.In paragraph 1(1) of Schedule 1 (certification of British films...

        7. Airports Act 1986 (c. 31)

          1. 320.The Airports Act 1986 is amended as follows.

          2. 321.In section 77(3) (corporation tax) for “Chapter II of Part...

        8. Finance Act 1986 (c. 41)

          1. 322.The Finance Act 1986 is amended as follows.

          2. 323.In section 78(7)(d) (loan capital) after “2005” insert “ or...

          3. 324.In section 79 (loan capital: new provisions)—

          4. 325.In section 99(9A) (interpretation) after “2005” insert “ or section...

        9. Gas Act 1986 (c. 44)

          1. 326.The Gas Act 1986 is amended as follows.

          2. 327.In section 60(3) (tax provisions) for “Chapter II of Part...

        10. British Steel Act 1988 (c. 35)

          1. 328.The British Steel Act 1988 is amended as follows.

          2. 329.In section 11(7) (corporation tax) for “Chapter II of Part...

        11. Finance Act 1988 (c. 39)

          1. 330.The Finance Act 1988 is amended as follows.

          2. 331.Omit section 65 (commercial woodlands).

          3. 332.Omit section 66 (company residence).

          4. 333.Omit section 66A (residence of SE or SCE).

          5. 334.Omit section 73(2) to (4) (consideration for certain restrictive undertakings)....

          6. 335.Omit Schedule 6 (commercial woodlands).

          7. 336.Omit Schedule 7 (exceptions to the rule in section 66(1))....

          8. 337.In paragraph 3 of Schedule 12 (building societies: change of...

        12. Finance Act 1989 (c. 26)

          1. 338.The Finance Act 1989 is amended as follows.

          2. 339.Omit section 43 (Schedule D: computation (unpaid remuneration)).

          3. 340.Omit section 44 (companies with investment business and insurance companies:...

          4. 341.In section 82(1) (calculation of profits: bonuses etc) for the...

          5. 342.In section 82D(2) (treatment of profits: life assurance_adjustment consequent on...

          6. 343.In section 82E(7) (section 82D: treatment of transferors under insurance...

          7. 344.(1) Amend section 83 (receipts to be taken into account)...

          8. 345.(1) Amend section 83YC (FAFTS: charge in relevant period of...

          9. 346.In section 83YD(3)(a) (FAFTS: deduction in subsequent periods of account)...

          10. 347.(1) Amend section 83YF (financial reinsurance arrangements: further provision) as...

          11. 348.(1) Amend section 85 (charge of certain receipts of basic...

          12. 349.(1) Amend section 85A (excess adjusted Case I profits) as...

          13. 350.In section 88(3)(b) (corporation tax: policy holders' share of profits)...

          14. 351.(1) Amend section 89 (policy holders' share of profits) as...

        13. Finance Act 1990 (c. 29)

          1. 352.The Finance Act 1990 is amended as follows.

          2. 353.Omit section 126(2) and (3) (pools payments for football ground...

          3. 354.In Schedule 14 (amendments correcting errors in ICTA) omit paragraph...

        14. Finance Act 1991 (c. 31)

          1. 355.The Finance Act 1991 is amended as follows.

          2. 356.For section 65(5) (reimbursement by defaulter in respect of certain...

          3. 357.Omit section 121(2) and (3) (pools payments to support games...

        15. Taxation of Chargeable Gains Act 1992 (c. 12)

          1. 358.The Taxation of Chargeable Gains Act 1992 is amended as...

          2. 359.In section 1(2) (the charge to tax) for “section 6...

          3. 360.In section 10B (non-resident company with United Kingdom permanent establishment)...

          4. 361.In section 33A (value shifting: modification of sections 30 to...

          5. 362.In section 40(4) (interest charged to capital) after “relationships)” insert...

          6. 363.In section 41(4) (restriction of losses by reference to capital...

          7. 364.In section 48(4) (consideration due after time of disposal) for...

          8. 365.(1) Amend section 59 (partnerships) as follows.

          9. 366.(1) Amend section 116 (reorganisations, conversions and reconstructions) as follows....

          10. 367.After section 116 insert— Holding beginning or ceasing to fall...

          11. 368.In section 117(6D) (meaning of “qualifying corporate bond”) after “section...

          12. 369.In section 143(1) (commodity and financial futures and qualifying options)—...

          13. 370.After section 151D insert— Exchange gains and losses from loan...

          14. 371.In section 156(4) (assets of Class 1)—

          15. 372.After section 156 insert— Intangible fixed assets: roll-over relief (1) This section applies if a company is entitled to...

          16. 373.In section 158(2) (activities other than trades, and interpretation) omit...

          17. 374.In section 161(3)(a) (appropriations to and from stock) for “under...

          18. 375.In section 170(9)(c) (interpretation of sections 171 to 181) omit...

          19. 376.In section 171(3A) (transfers within a group: general provisions) for...

          20. 377.Omit section 201(2) (relationship between section 201 of TCGA 1992...

          21. 378.For section 203(1) substitute— (1) Sections 274 to 276 of...

          22. 379.(1) Amend section 210A (ring-fencing of losses) as follows.

          23. 380.(1) Amend section 241 (furnished holiday lettings) as follows.

          24. 381.In section 251(8) (general provisions) omit— (a) paragraph (a), and...

          25. 382.In section 253(3) (relief for loans to traders) for “Chapter...

          26. 383.In section 275B (section 275A: supplementary provisions) for subsection (3)...

          27. 384.After section 286 insert— Residence of companies Chapter 3 of Part 2 of CTA 2009 (rules for...

          28. 385.In section 288(1) (interpretation)— (a) at the appropriate place insert—...

          29. 386.In Schedule 7AC (exemptions for disposals by companies with substantial...

          30. 387.In Schedule 7D (approved share schemes and share incentives), in...

          31. 388.(1) Amend Schedule 8 (leases) as follows.

        16. Finance (No. 2) Act 1992 (c. 48)

          1. 389.The Finance ( No. 2) Act 1992 is amended as...

          2. 390.(1) Amend paragraph 3 of Schedule 12 (banks etc in...

        17. Finance Act 1994 (c. 9)

          1. 391.The Finance Act 1994 is amended as follows.

          2. 392.(1) Amend section 219 (Lloyd's underwriters: taxation of profits) as...

          3. 393.In section 220(3) (accounting period in which certain profits or...

          4. 394.In section 225(4) (stop-loss and quota share insurance) in the...

          5. 395.In section 226(3) (provisions which are not to apply) for...

          6. 396.In section 229(1)(ca) (regulations) for sub-paragraph (ii) substitute—

          7. 397.Omit sections 249 and 250 (certain companies treated as non-resident)....

          8. 398.In paragraph 20(1) of Schedule 24 (provisions relating to the...

        18. Finance Act 1995 (c. 4)

          1. 399.The Finance Act 1995 is amended as follows.

          2. 400.In section 126(7A) (UK representatives of non-residents) omit paragraph (b)...

          3. 401.In section 127(1) (persons not treated as UK representatives)—

        19. Finance Act 1996 (c. 8)

          1. 402.The Finance Act 1996 is amended as follows.

          2. 403.Omit section 80 (taxation of loan relationships).

          3. 404.Omit section 81 (meaning of “loan relationship” etc).

          4. 405.Omit section 82 (methods of bringing amounts into account).

          5. 406.Omit section 83 (non-trading deficit on loan relationships).

          6. 407.Omit section 84 (debits and credits brought into account).

          7. 408.Omit section 84A (exchange gains and losses from loan relationships)....

          8. 409.Omit section 85A (computation in accordance with generally accepted accounting...

          9. 410.Omit section 85B (amounts recognised in determining a company's profit...

          10. 411.Omit section 85C (amounts not fully recognised for accounting purposes)....

          11. 412.Omit section 87 (accounting method where parties have a connection)....

          12. 413.Omit section 87A (meaning of “control” in section 87).

          13. 414.Omit section 88 (exemption from section 87 in certain cases)....

          14. 415.Omit section 88A (accounting method where rate of interest is...

          15. 416.Omit section 90A (change of accounting basis applicable to assets...

          16. 417.Omit section 91A (shares subject to outstanding third party obligations)....

          17. 418.Omit section 91B (non-qualifying shares).

          18. 419.Omit section 91C (Condition 1 for section 91B(6)(b)).

          19. 420.Omit section 91D (Condition 2 for section 91B(6)(b)).

          20. 421.Omit section 91E (Condition 3 for section 91B(6)(b)).

          21. 422.Omit section 91F (power to add, vary or remove Conditions...

          22. 423.Omit section 91G (shares beginning or ceasing to be subject...

          23. 424.Omit section 91H (payments in return for capital contribution).

          24. 425.Omit section 91I (change of partnership shares).

          25. 426.Omit section 93C (creditor relationships and benefit derived by connected...

          26. 427.Omit section 94 (indexed gilt-edged securities).

          27. 428.Omit section 94A (loan relationships with embedded derivatives).

          28. 429.Omit section 94B (loan relationships treated differently by connected debtor...

          29. 430.Omit section 95 (gilt strips).

          30. 431.Omit section 96 (special rules for certain other gilts).

          31. 432.Omit section 97 (manufactured interest).

          32. 433.Omit section 98 (collective investment schemes).

          33. 434.Omit section 99 (insurance companies).

          34. 435.Omit section 100 (money debts etc not arising from the...

          35. 436.Omit section 101 (financial instruments).

          36. 437.Omit section 103 (interpretation of Chapter).

          37. 438.In section 154 (FOTRA securities), omit subsections (2), (3), (5),...

          38. 439.In section 203(9) (modification of the Agriculture Act 1993) for...

          39. 440.Omit Schedule 8 (loan relationships: claims etc relating to deficits)....

          40. 441.Omit Schedule 9 (loan relationships: special computational provisions).

          41. 442.Omit Schedule 10 (loan relationships: collective investment schemes).

          42. 443.Omit Schedule 11 (loan relationships: special provisions for insurers).

          43. 444.(1) Amend Schedule 15 (loan relationships: savings and transitional provisions)...

        20. Broadcasting Act 1996 (c. 55)

          1. 445.The Broadcasting Act 1996 is amended as follows.

          2. 446.(1) Amend Schedule 7 (transfer schemes relating to BBC transmission...

        21. Finance Act 1997 (c. 16)

          1. 447.The Finance Act 1997 is amended as follows.

          2. 448.In Schedule 12 (leasing arrangements: finance leases and loans), in...

        22. Finance (No. 2) Act 1997 (c. 58)

          1. 449.The Finance (No. 2) Act 1997 is amended as follows....

          2. 450.Omit section 40 (carry-back of loan relationship deficits).

        23. Finance Act 1998 (c. 36)

          1. 451.The Finance Act 1998 is amended as follows.

          2. 452.Omit section 42 (computation of profits of trade, profession or...

          3. 453.In section 46 (minor and consequential provisions about computations) omit...

          4. 454.(1) Amend Schedule 18 (company tax returns, assessments and related...

        24. Finance Act 1999 (c. 16)

          1. 455.The Finance Act 1999 is amended as follows.

          2. 456.Omit section 54 (tax treatment of reverse premiums).

          3. 457.Omit section 63 (treatment of transfer fees under existing contracts)....

          4. 458.(1) Amend section 81 (acquisitions disregarded under insurance companies concession)...

          5. 459.Omit Schedule 6 (tax treatment of receipts by way of...

        25. Commonwealth Development Corporation Act 1999 (c. 20)

          1. 460.The Commonwealth Development Corporation Act 1999 is amended as follows....

          2. 461.(1) Amend paragraph 6 of Schedule 3 (tax) as follows....

        26. Finance Act 2000 (c. 17)

          1. 462.The Finance Act 2000 is amended as follows.

          2. 463.(1) Amend section 46 (exemption for small trades etc) as...

          3. 464.Omit section 50 (phasing out of relief for payments to...

          4. 465.Omit section 69(1) (which introduces Schedule 20).

          5. 466.Omit section 143(2) (power to provide incentives to use electronic...

          6. 467.In Schedule 12 (provision of services through an intermediary) omit...

          7. 468.In Schedule 15 (the corporate venturing scheme) in paragraph 60(1)...

          8. 469.Omit Schedule 20 (tax relief for expenditure on research and...

          9. 470.(1) Amend Schedule 22 (tonnage tax) as follows.

        27. Transport Act 2000 (c. 38)

          1. 471.The Transport Act 2000 is amended as follows.

          2. 472.(1) Amend Schedule 7 (transfer schemes: tax) as follows.

          3. 473.(1) Amend Schedule 26 (transfers: tax) as follows.

        28. Capital Allowances Act 2001 (c. 2)

          1. 474.The Capital Allowances Act 2001 is amended as follows.

          2. 475.In section 2(4) (general means of giving effect to capital...

          3. 476.In section 15(1)(f) (qualifying activities) for “section 55(2) of ICTA”...

          4. 477.In section 16 (ordinary property business) omit “, or a...

          5. 478.(1) Amend section 17 (furnished holiday lettings) as follows.

          6. 479.(1) Amend section 18 (managing investments of a company with...

          7. 480.In section 28(2B)(a) (thermal insulation of buildings) for “section 31ZA...

          8. 481.In section 38 (production animals etc) for paragraphs (a) and...

          9. 482.(1) Amend section 63 (cases in which disposal value is...

          10. 483.In section 105(3)(a) (“profits chargeable to tax”) for “section 830(4)...

          11. 484.(1) Amend section 106 (the designated period) as follows.

          12. 485.(1) Amend section 108 (effect of disposal to connected person...

          13. 486.(1) Amend section 112 (excess allowances: connected persons) as follows....

          14. 487.(1) Amend section 115 (prohibited allowances: connected persons) as follows....

          15. 488.(1) Amend section 122 (short-term leasing by buyer, lessee, etc)...

          16. 489.(1) Amend section 125 (other qualifying purposes) as follows.

          17. 490.In section 252 (mines, transport undertakings etc) for “section 55(2)...

          18. 491.(1) Amend section 253 (companies with investment business) as follows....

          19. 492.(1) Amend section 256 (different giving effect rules for different...

          20. 493.In section 257(2)(a) (supplementary) for “Case I” substitute “ life...

          21. 494.In section 260(8) (special leasing: corporation tax (excess allowance)) for...

          22. 495.(1) Amend section 263 (qualifying activities carried on in partnership)...

          23. 496.(1) Amend section 265 (successions: general) as follows.

          24. 497.In section 282 (buildings outside the United Kingdom) for the...

          25. 498.In section 291(3)(a) (supplementary provisions with respect to elections) for...

          26. 499.In section 326(1) (interpretation of section 325), in the definition...

          27. 500.In section 331(1)(b) (meaning of “capital value”) for sub-paragraph (i)...

          28. 501.(1) Amend section 353 (lessors and licensors) as follows.

          29. 502.(1) Amend section 354 (buildings temporarily out of use) as...

          30. 503.In section 390(1) (interpretation of section 389), in the definition...

          31. 504.(1) Amend section 392 (UK property business and Schedule A...

          32. 505.In section 393B(4) (meaning of “qualifying expenditure”) omit “or Schedule...

          33. 506.In section 393J(3)(a) (entitlement to writing-down allowances) for “section 38(1)...

          34. 507.(1) Amend section 393T (giving effect to allowances and charges)...

          35. 508.(1) Amend section 406 (reduction where premium relief previously allowed)...

          36. 509.In section 454(1)(c) (qualifying expenditure) for “section 531(3)(a) of ICTA”...

          37. 510.In section 455(4) (excluded expenditure) for “section 531(2) of ICTA”...

          38. 511.In section 462(3) (disposal values) for “section 531(2) of ICTA”...

          39. 512.In section 481(5)(b) (anti-avoidance: limit on qualifying expenditure) for “section...

          40. 513.In section 483(c) (meaning of “income from patents”) for “section...

          41. 514.In section 488(3)(a) (balancing allowances) for “section 18 of ITTOIA...

          42. 515.(1) Amend section 529 (giving effect to allowances and charges)...

          43. 516.In section 536(5)(a)(v) (contributions not made by public bodies and...

          44. 517.In section 545(4) (investment assets) for “Case I of Schedule...

          45. 518.(1) Amend section 558 (effect of partnership changes) as follows....

          46. 519.(1) Amend section 559 (effect of successions) as follows.

          47. 520.(1) Amend section 577 (other definitions) as follows.

          48. 521.(1) Amend Schedule A1 (first-year tax credits) as follows.

          49. 522.(1) Amend Schedule 1 (abbreviations and defined expressions) as follows....

        29. Finance Act 2001 (c. 9)

          1. 523.The Finance Act 2001 is amended as follows.

          2. 524.Omit section 70(1) and (2) (which introduces Schedule 22).

          3. 525.Omit Schedule 22 (remediation of contaminated land).

        30. Finance Act 2002 (c. 23)

          1. 526.The Finance Act 2002 is amended as follows.

          2. 527.Omit section 53 (which introduces Schedule 12 to that Act)....

          3. 528.Omit section 54 (which introduces Schedules 13 and 14 to...

          4. 529.Omit section 55 (gifts of medical supplies and equipment).

          5. 530.Omit section 64 (adjustment on change of basis).

          6. 531.(1) Amend section 65 (postponement of change to mark to...

          7. 532.Omit section 71 (accounting method where rate of interest etc...

          8. 533.In section 81(3)(b) (transitional provision) for “Chapter 2 of Part...

          9. 534.In section 83 (derivative contracts) omit subsections (1)(a) and (2)....

          10. 535.Omit section 84(1) (gains and losses from intangible fixed assets...

          11. 536.Omit Schedule 12 (tax relief for expenditure on research and...

          12. 537.Omit Schedule 13 (tax relief for expenditure on vaccine research...

          13. 538.In Schedule 16 (community investment tax relief) in paragraph 27(4)...

          14. 539.(1) Amend Schedule 18 (relief for community amateur sports clubs)...

          15. 540.Omit Schedule 22 (computation of profits: adjustment on change of...

          16. 541.(1) Amend Schedule 23 (exchange gains and losses from loan...

          17. 542.In Schedule 25 (loan relationships) omit paragraphs 61 to 64....

          18. 543.Omit Schedule 26 (derivative contracts).

          19. 544.(1) Schedule 28 (derivative contracts: transitional provisions etc) is amended...

          20. 545.Omit Schedule 29 (gains and losses of a company from...

        31. Proceeds of Crime Act 2002 (c. 29)

          1. 546.The Proceeds of Crime Act 2002 is amended as follows....

          2. 547.(1) Amend Schedule 10 (tax) as follows.

        32. Income Tax (Earnings and Pensions) Act 2003 (c. 1)

          1. 548.The Income Tax (Earnings and Pensions) Act 2003 is amended...

          2. 549.In section 61(1) (interpretation) in the definition of “business” for...

          3. 550.In section 178(d) (exception for loans where interest qualifies for...

          4. 551.In section 180(5)(d) (threshold for benefit of loan to be...

          5. 552.(1) Amend section 357 (business entertainment and gifts: exception where...

          6. 553.In section 420(1)(h) (meaning of securities etc) at the end...

          7. 554.(1) Amend section 515 (which refers to other provisions which...

          8. 555.In section 702(5B) (which sets out what shares are corporation...

          9. 556.In Schedule 1 (abbreviations and defined expressions)—

          10. 557.In Schedule 2 (approved share incentive plans), in paragraph 85(1)(c),...

        33. Finance Act 2003 (c. 14)

          1. 558.The Finance Act 2003 is amended as follows.

          2. 559.Omit section 141 (corporation tax for employee share acquisitions).

          3. 560.Omit section 143 (restriction of deductions for employee benefit contributions)....

          4. 561.In section 148 (meaning of “permanent establishment”)—

          5. 562.(1) Amend section 150 (non-resident companies: assessment, collection and recovery...

          6. 563.In section 152(2) (non-resident companies: transactions carried out through broker,...

          7. 564.After section 177(4) (currency contracts and currency options) insert—

          8. 565.In section 195(9)(b) (companies acquiring their own shares) for the...

          9. 566.Omit Schedule 23 (corporation tax relief for employee share acquisitions)....

          10. 567.Omit Schedule 24 (restriction of deductions for employee benefit contributions)....

          11. 568.In paragraph 5A(2) of Schedule 26 (non-resident companies: transactions through...

        34. Finance Act 2004 (c. 12)

          1. 569.The Finance Act 2004 is amended as follows.

          2. 570.In section 71 (collection and recovery of sums to be...

          3. 571.Other enactments

          4. 572.(1) Amend section 131 (companies in partnership) as follows.

          5. 573.(1) Amend section 196 (relief for employers in respect of...

          6. 574.In section 196A(4) (power to restrict relief)—

          7. 575.In section 197(10) (spreading of relief)— (a) in paragraph (a),...

          8. 576.In section 199A(10) (indirect contributions)— (a) in paragraph (a) for...

          9. 577.In section 200 (no other relief for employers in respect...

          10. 578.(1) Amend section 246 (restriction of deduction for non-contributory provision)...

          11. 579.In section 246A(4) (case where no relief for provision by...

          12. 580.In section 280(1) (abbreviations and general index)—

          13. 581.(1) Amend Schedule 26 (offshore funds) as follows.

        35. Energy Act 2004 (c. 20)

          1. 582.The Energy Act 2004 is amended as follows.

          2. 583.(1) Amend section 27 (tax exemption for NDA activities) as...

          3. 584.(1) Amend section 28 (taxation of activities of the Nuclear...

          4. 585.In section 44(2) (extinguishment of BNFL losses for tax purposes)—...

          5. 586.(1) Amend Schedule 9 (taxation provisions relating to nuclear transfer...

        36. Income Tax (Trading and Other Income) Act 2005 (c. 5)

          1. 587.The Income Tax (Trading and Other Income) Act 2005 is...

          2. 588.In section 22(2)(b) (payments for wayleaves) for “would otherwise be...

          3. 589.(1) Amend section 48 (car or motor cycle hire) as...

          4. 590.In section 49(2)(b) (car or motor cycle hire: supplementary) after...

          5. 591.In section 60(6) (tenants under taxed leases: introduction) after “288”...

          6. 592.(1) Amend section 64 (restriction on section 61 expenses: lease...

          7. 593.In section 65(1)(a) (restrictions on section 61 expenses: lease of...

          8. 594.In the title of section 66 (corporation tax receipts treated...

          9. 595.(1) Amend section 67 (restrictions on section 61 expenses: corporation...

          10. 596.(1) Amend section 71 (educational establishments) as follows.

          11. 597.Omit section 79(2) (additional payments: change in persons carrying on...

          12. 598.After section 79 insert— Additional payments: change in the persons...

          13. 599.In section 80(2) (payments made by the Government) for “79”...

          14. 600.In section 88(6)(b) (payments to research associations, universities etc) before...

          15. 601.(1) Amend section 155 (levies and repayments under FISMA 2000)...

          16. 602.In section 158(1)(d) (lease premiums etc: reduction of receipts) for...

          17. 603.In section 170(3)(b) (deduction for capital expenditure) for “section 91(1)(b)...

          18. 604.In section 171(2)(d) (allocation of ancillary capital expenditure) for “section...

          19. 605.In section 175(2) (basis of valuation of trading stock)—

          20. 606.In section 176(1)(a) (sale basis of valuation: sale to unconnected...

          21. 607.In section 177(1)(a) (sale basis of valuation: sale to connected...

          22. 608.In section 178(1)(a) (sale basis of valuation: election by connected...

          23. 609.(1) Amend section 180 (cost to buyer of stock valued...

          24. 610.In section 184(1) (basis of valuation of work in progress)—...

          25. 611.In section 194(7) (disposal of know-how as part of disposal...

          26. 612.In section 246(2) (basic meaning of “post-cessation receipt”) for the...

          27. 613.In section 249(3) (debts released after cessation) for the words...

          28. 614.In section 276(3) (introduction to Chapter 4 of Part 3)...

          29. 615.In section 279(3) for “or of” substitute “ of or...

          30. 616.In the title of section 281 (sums payable for variation...

          31. 617.(1) Amend section 287 (circumstances in which additional calculation rule...

          32. 618.(1) Amend section 288 (the additional calculation rule) as follows....

          33. 619.(1) Amend section 290 (meaning of “unused amount” and “unreduced...

          34. 620.(1) Amend section 293 (restrictions on section 292 expenses: the...

          35. 621.For section 294(1)(c) (restriction on section 292 expenses: lease of...

          36. 622.For section 295(2)(b) (limit on reductions and deductions) substitute—

          37. 623.In section 296(1)(a) (corporation tax receipts treated as taxed receipts)...

          38. 624.In section 298 (taking account of deductions for rent as...

          39. 625.In section 299(1)(b) (payment of tax by instalments) for “term”...

          40. 626.(1) Amend section 303 (rules for determining effective duration of...

          41. 627.(1) Amend section 304 (applying the rules in section 303)...

          42. 628.In section 318(4) for “section 30 of ICTA” substitute “...

          43. 629.(1) Amend section 356 (application to Schedule A businesses) as...

          44. 630.In section 413(4) (person liable) for paragraph (b) substitute—

          45. 631.In section 419(2) (loans and advances to persons who die)...

          46. 632.In section 466(3) (person liable: personal representatives) for “section 701(8)...

          47. 633.In section 496(7) (modification of section 494: qualifying endowment policies...

          48. 634.In section 671 (successive absolute interests)— (a) at the end...

          49. 635.After section 749 insert— Interest on tax overpaid No liability to income tax arises in respect of interest...

          50. 636.In section 754(1) (redemption of funding bonds) for “section 582(1)...

          51. 637.(1) Amend section 839 (annual payments payable out of relevant...

          52. 638.In section 847(2) (partnerships: general provisions), in the words before...

          53. 639.In section 849 (calculation of firm's profits or losses) after...

          54. 640.For section 850 (allocation of firm's profits or losses between...

          55. 641.(1) Amend section 860 (adjustment income) as follows.

          56. 642.For section 861 (sale of patent rights: effect of partnership...

          57. 643.(1) Amend section 862 (sale of patent rights: effect of...

          58. 644.Omit section 881 (disapplication of corporation tax: section 9 of...

          59. 645.(1) Amend Schedule 1 (consequential amendments) as follows.

          60. 646.(1) Amend Schedule 2 (transitionals and savings etc) as follows....

          61. 647.(1) Amend Schedule 4 (abbreviations and defined expressions) as follows....

        37. Finance Act 2005 (c. 7)

          1. 648.The Finance Act 2005 is amended as follows.

          2. 649.In section 47A(6) (alternative finance arrangements: diminishing shared ownership) for...

          3. 650.In section 48A (alternative finance arrangements: alternative finance bond: introduction)...

          4. 651.In section 48B (alternative finance arrangements: alternative finance investment bond:...

          5. 652.In section 49(2) (alternative finance arrangements: deposit) for “profit share...

          6. 653.In section 49A (alternative finance arrangements: profit share agency)—

          7. 654.Omit section 50 (treatment of alternative finance arrangements: companies).

          8. 655.In section 51 (treatment of alternative finance arrangements: persons other...

          9. 656.In section 52 (provision not at arm's length)—

          10. 657.Omit section 54 (return not to be treated as distribution)....

          11. 658.In section 54A (treatment of section 47, 49 and 49A...

          12. 659.In section 55 (further provisions) omit “, corporation tax”.

          13. 660.In section 56 (application of Chapter)— (a) in subsections (2)...

          14. 661.In section 57 (interpretation of Chapter)— (a) in the definition...

          15. 662.In section 83(8) (application of accounting standards to securitisation companies)...

          16. 663.In section 105 (interpretation) after the definition of “CAA 2001”...

          17. 664.(1) Amend Schedule 2 (alternative finance arrangements: further provisions) as...

          18. 665.In Schedule 4 (accounting practice and related matters) omit paragraphs...

        38. Railways Act 2005 (c. 14)

          1. 666.The Railways Act 2005 is amended as follows.

          2. 667.(1) Amend Schedule 10 (taxation provisions relating to transfer schemes)...

        39. Finance (No. 2) Act 2005 (c. 22)

          1. 668.The Finance (No. 2) Act 2005 is amended as follows....

          2. 669.In section 18 (section 17(3): specific powers) for subsection (2)(c)...

          3. 670.(1) Amend section 26 (receipts cases) as follows.

          4. 671.In section 27(2) (rule as to qualifying payment) for the...

          5. 672.In section 71 (interpretation) after the definition of “CAA 2001”...

          6. 673.In Schedule 6 (accounting practice and related matters)—

          7. 674.In Schedule 7 (avoidance involving financial arrangements) in paragraph 14—...

        40. Finance Act 2006 (c. 25)

          1. 675.The Finance Act 2006 is amended as follows.

          2. 676.Omit sections 31 to 41 (provisions about films, in particular...

          3. 677.In section 42(2) (film tax relief: further provisions) omit—

          4. 678.Omit sections 43 to 45 (film losses).

          5. 679.At the end of each of sections 46 and 47...

          6. 680.Omit sections 48 to 50 (sound recordings).

          7. 681.Omit section 52 (films: application of provisions to certain films...

          8. 682.Omit section 53(2) (films and sound recordings: commencement etc).

          9. 683.In section 97 (beneficial loans to employees)—

          10. 684.In section 104(1) (property rental business)— (a) in paragraph (a)—...

          11. 685.In section 112 (entry charge) for subsection (1) substitute—

          12. 686.In section 115(4) (profit: financing-cost ratio)— (a) in paragraph (a)...

          13. 687.In section 117(3)(b) (cancellation of tax advantage) omit “under Case...

          14. 688.(1) Amend section 120 (calculation of profits) as follows.

          15. 689.(1) Amend section 121 (distributions: liability to tax) as follows....

          16. 690.In section 136(2) (availability of group reliefs) for paragraphs (d)...

          17. 691.In section 139(2) (manufactured dividends), in the provision substituted for...

          18. 692.In section 179 (interpretation) after the definition of “CAA 2001”...

          19. 693.Omit Schedule 4 (taxation of activities of film production company)....

          20. 694.In Schedule 5 (film tax relief: further provisions)—

          21. 695.(1) Amend Schedule 10 (sale etc of lessor companies etc...

          22. 696.(1) Amend Schedule 15 (accountancy change: spreading of adjustment), Part...

          23. 697.(1) Amend Schedule 16 (real estate investment trusts: excluded business...

          24. 698.(1) Amend Schedule 17 (group real estate investment trusts: modifications)...

        41. Income Tax Act 2007 (c. 3)

          1. 699.The Income Tax Act 2007 is amended as follows.

          2. 700.For section 5 substitute— Income tax and companies Section 3 of CTA 2009 disapplies the provisions of the...

          3. 701.In section 276(3) (conditions relating to income) for “paragraph 14(3)...

          4. 702.In section 489(6) (the “applicable period” in relation to shares)...

          5. 703.In section 550(a) (meaning of “relievable gift”) for “section 83A...

          6. 704.In section 557(1)(b)(ii) (substantial donor transactions: supplementary) after “2005” insert...

          7. 705.(1) Amend section 835 (residence rules for trustees and companies)...

          8. 706.After section 835 insert— Residence of companies Chapter 3 of Part 2 of CTA 2009 (rules for...

          9. 707.In section 899(4)(b) (meaning of “qualifying annual payment”) for “charged...

          10. 708.In section 904 (annual payments for dividends or non-taxable consideration)...

          11. 709.(1) Amend section 910 (proceeds of a sale of patent...

          12. 710.In section 934(4) (non-UK resident companies) for “section 11(2) of...

          13. 711.In section 937(5)(c) (partnerships)— (a) for “section 11(2) of ICTA”...

          14. 712.In section 939(1)(b) (duty to retain bonds where issue treated...

          15. 713.(1) Amend section 941 (deemed payments to unit holders and...

          16. 714.In section 948(2) (meaning of “accounting period”) for the words...

          17. 715.In section 965(2) (overview of sections 966 to 970) for...

          18. 716.(1) Amend section 971 (income tax in respect of non-resident...

          19. 717.In section 976(6) (arrangements for payments of interest less tax...

          20. 718.In section 980(2) (derivative contracts: exception from duties to deduct)...

          21. 719.In section 989 (definitions) omit the definition of “Schedule A...

          22. 720.In section 1017 (abbreviated references to Acts) after the definition...

          23. 721.In Schedule 4 (index of defined expressions) omit the entry...

        42. Finance Act 2007 (c. 11)

          1. 722.The Finance Act 2007 is amended as follows.

          2. 723.In section 113 (interpretation) after the definition of “CRCA 2005”...

          3. 724.In Schedule 3 (managed service companies) omit paragraph 10.

          4. 725.(1) Amend Schedule 7 (insurance business: gross roll-up business etc)...

          5. 726.(1) Amend Schedule 13 (sale and repurchase of securities) as...

          6. 727.In paragraph 28(fa) of Schedule 24 (penalties for errors)—

        43. Finance Act 2008 (c. 9)

          1. 728.The Finance Act 2008 is amended as follows.

          2. 729.Omit section 29 (cap on R&D aid).

          3. 730.Omit section 36(1) (company gains from investment life insurance contracts...

          4. 731.In section 77(6), in the words after paragraph (b) for...

          5. 732.In section 154(6) (stamp duty and stamp duty reserve tax:...

          6. 733.In section 165(1) (interpretation) after the definition of “CRCA 2005”...

          7. 734.In Schedule 10 (cap on R&D aid), omit paragraphs 1...

          8. 735.Omit Schedule 13 (company gains from investment life insurance contracts)....

          9. 736.In Schedule 15 (changes in trading stock), omit Part 2....

          10. 737.In Schedule 25 (first-year tax credits)— (a) in paragraph 14(6)(b)...

        44. Crossrail Act 2008 (c. 18)

          1. 738.The Crossrail Act 2008 is amended as follows.

          2. 739.(1) Amend Schedule 13 (transfer schemes: tax provisions) as follows....

    2. SCHEDULE 2

      Transitionals and savings

      1. Part 1 General provisions

        1. Continuity of the law: general

          1. 1.The repeal of provisions and their enactment in a rewritten...

          2. 2.Paragraph 1 does not apply to any change made by...

          3. 3.Any subordinate legislation or other thing which—

          4. 4.(1) Any reference (express or implied) in this Act, another...

          5. 5.(1) Any reference (express or implied) in any enactment, instrument...

          6. 6.Paragraphs 1 to 5 have effect instead of section 17(2)...

          7. 7.Paragraphs 4 and 5 apply only so far as the...

        2. General saving for old transitional provisions and savings

          1. 8.(1) The repeal by this Act of a transitional or...

        3. Interpretation

          1. 9.(1) In this Part— “enactment” includes subordinate legislation (within the...

      2. Part 2 Changes in the law

        1. 10.(1) This paragraph applies if, in the case of any...

      3. Part 3 Charge to corporation tax on income

        1. Effect of repeal of section 9(1) of ICTA on relevance of case law

          1. 11.The repeal by this Act of section 9(1) of ICTA...

      4. Part 4 Accounting periods

        1. Companies in administration

          1. 12.Section 10(1)(i) and (j), (2), (3) and (4) apply only...

      5. Part 5 Company residence: exceptions to section 14

        1. 13.(1) Subject to sub-paragraph (2), section 14 does not apply...

        2. 14.(1) Subject to sub-paragraph (2), section 14 does not apply...

        3. 15.(1) In paragraph 13— “general consent” means a consent under...

      6. Part 6 Trading income

        1. Hiring cars with low CO emissions before 1 April 2013

          1. 16.Section 58 does not apply to expenditure which is incurred...

          2. 17.In relation to expenditure incurred on the hiring of a...

        2. Tenants under taxed leases

          1. 18.(1) This paragraph relates to the operation of sections 62...

          2. 19.(1) This paragraph provides for the application of section 63...

          3. 20.(1) This paragraph provides for the application of section 63...

        3. Local enterprise agencies

          1. 21.To the extent that any function of the Scottish Ministers...

        4. Expenses connected with patents, designs and trade marks

          1. 22.(1) This paragraph applies if— (a) fees have been incurred,...

        5. Payments to Export Credits Guarantee Department

          1. 23.(1) This paragraph applies if— (a) a sum is payable,...

        6. Reverse premiums

          1. 24.(1) Sections 98 and 99 do not apply to a...

        7. Sums recovered under insurance policies etc

          1. 25.Section 103 does not apply if— (a) a company carrying...

        8. Meaning of “designated educational establishment”

          1. 26.To the extent that the power of the Welsh Ministers...

          2. 27.The reference in section 106(1)(a) to regulations made for England...

        9. Dealers in securities etc

          1. 28.The repeal by this Act of section 473(2B) of ICTA...

        10. Purchase or sale of woodlands

          1. 29.Section 134 does not apply if the purchase mentioned in...

        11. Waste disposal

          1. 30.If the predecessor ceased to carry on the trade carried...

          2. 31.If the trade carried on by the trader was started...

          3. 32.Section 144(3) does not apply for the purposes of sections...

        12. Reserves of marketing authorities etc

          1. 33.In section 153(5) “approved scheme or arrangement” includes a scheme...

        13. Adjustment on change of basis

          1. 34.Chapter 14 of Part 3 applies to a change of...

      7. Part 7 Property income

        1. Lease premiums

          1. 35.Section 217 does not apply in relation to a lease...

        2. Lease premiums: sums payable instead of rent

          1. 36.Section 219 does not apply in relation to a lease...

        3. Lease premiums: sums payable for surrender of lease

          1. 37.Section 220 does not apply in relation to a lease...

        4. Lease premiums: assignments for profit of lease granted at undervalue

          1. 38.Section 222 does not apply in relation to a lease...

        5. Lease premiums: pre-commencement receipts under ICTA treated as taxed receipts

          1. 39.(1) This paragraph relates to the operation of sections 227...

        6. Lease premiums: taking account of reductions under section 37(2) or (3) of ICTA

          1. 40.(1) This paragraph applies if— (a) in calculating the amount...

        7. Lease premiums: taking account of deductions for rent as a result of section 37(4) or 87(2) of ICTA

          1. 41.(1) Sub-paragraph (2) applies if— (a) in calculating the profits...

        8. Lease premiums: time limits for claims for repayment of tax

          1. 42.(1) Until the Treasury by order appoints a day under...

        9. Lease premiums: rules for determining effective duration of lease

          1. 43.(1) In relation to a lease granted after 24 August...

          2. 44.The amendments made by paragraph 626 of Schedule 1 (amendments...

          3. 45.(1) In relation to a lease granted after 12 June...

          4. 46.(1) In relation to a lease granted before 13 June...

          5. 47.The amendments made by paragraphs 498 and 506 of Schedule...

        10. Lease premiums: meaning of “premium”

          1. 48.(1) In relation to a lease granted after 12 June...

        11. Reverse premiums

          1. 49.(1) Section 250 does not apply to a reverse premium—...

        12. Deductions for expenditure on energy-saving items

          1. 50.Sections 251 to 253 do not apply to expenditure incurred...

        13. Adjustment on change of basis

          1. 51.(1) Sections 261 and 262 apply to a change of...

        14. Meaning of “mineral royalties”

          1. 52.The definition of “mineral royalties” in section 274(2) does not...

      8. Part 8 Loan relationships

        1. Interpretation

          1. 53.Except as provided in this Part of this Schedule, expressions...

        2. Opening and closing values determined under Schedule 15 to the Finance Act 1996

          1. 54.So far as immediately before the commencement of this Act...

        3. References to Part 5 to include Schedule 15 to FA 1996

          1. 55.Except where the context indicates otherwise, references to Part 5...

        4. Exemption for interest on tax overpaid for accounting periods ending before 1 July 1999

          1. 56.No liability to corporation tax arises in respect of interest...

        5. Regulations under section 81 of FA 2002

          1. 57.The repeal by this Act of any provision in Schedule...

        6. Continuity on transfers: transferees becoming party to loan relationship before 9 April 2003

          1. 58.(1) In determining whether Chapter 4 of Part 5 (continuity...

        7. Deeply discounted securities held before 1 October 2002

          1. 59.(1) This sub-paragraph applies if— (a) the condition in paragraph...

          2. 60.(1) This paragraph applies if— (a) an authorised unit trust...

        8. Restriction on bringing into account credits resulting from reversal of debits disallowed in a period of account beginning before 1 January 2005

          1. 61.(1) No credit is to be brought into account for...

        9. Disregard of pre-2005 disallowed debits

          1. 62.(1) This paragraph applies if in a period of account...

        10. Bringing into account losses on overseas sovereign debt etc

          1. 63.(1) This paragraph applies if at the end of the...

        11. Saving for old elections for treating loan relationships with embedded derivatives as two assets

          1. 64.(1) The repeal by this Act of paragraph 7 of...

        12. Deeply discounted securities of close companies: discounts for accounting periods beginning before 1 April 2007

          1. 65.(1) This paragraph applies as regards a debtor relationship entered...

        13. Repo, stock lending and other transactions before 1 October 2007: disapplication of section 332

          1. 66.Section 332 (repo, stock lending and other transactions) does not...

        14. Avoidance relying on continuity of treatment provisions: transactions before 16 May 2008

          1. 67.Section 347 (disapplication of Chapter 4 of Part 5 where...

        15. Disposals for consideration not fully recognised by accounting practice: disposals before 16 May 2008

          1. 68.Section 455 (disposals for consideration not fully recognised by accounting...

        16. 5½% Treasury Stock 2008-2012 not redeemed before 6 April 2009

          1. 69.(1) This paragraph applies if any loan relationship of a...

        17. References to Companies Act 2006

          1. 70.Until section 658 of the Companies Act 2006 (c. 46)...

        18. Prospective repeal of provisions concerning exchange gains and losses from loan relationships

          1. 71.(1) The following provisions (which rewrite provisions prospectively repealed by...

      9. Part 9 Relationships treated as loan relationships

        1. Relevant non-lending relationships: discounts accruing and profits arising before 16 March 2005

          1. 72.(1) None of the following is to be brought into...

        2. Relevant non-lending relationships: discounts on disposals before 22 March 2006

          1. 72A.(1) Section 480 (relevant non-lending relationships involving discounts) applies with...

        3. Alternative finance arrangements entered into before certain dates

          1. 73.(1) Chapter 6 of Part 6 (alternative finance arrangements) does...

        4. ...

          1. 74.(1) Chapter 6 of Part 6 (alternative finance arrangements) does...

        5. ...

          1. 75.(1) Chapter 6 of Part 6 (alternative finance arrangements) only...

        6. Shares with guaranteed returns: redeemable shares where public issue before 22 March 2006

          1. 76.In relation to any case where the public issue (within...

        7. Shares with guaranteed returns: income-producing assets for the increasing value condition

          1. 77.In relation to any time before 16 May 2008, section...

        8. Repo transactions and stock lending arrangements before 1 October 2007

          1. 78.(1) Chapter 10 of Part 6 (repos) does not apply...

      10. Part 10 Derivative contracts

        1. Interpretation

          1. 79.Expressions used in this Part of this Schedule and in...

        2. Extended meaning of reference in section 591(6)(b)

          1. 80.The reference in section 591(6)(b) (condition E) to the provisions...

        3. Disapplication of section 645

          1. 81.Section 645 (creditor relationships: embedded derivatives which are options) does...

        4. Existing assets representing creditor relationships: options

          1. 82.(1) This paragraph applies if section 645 would apply to...

          2. 83.(1) This paragraph applies for the purposes of paragraph 82....

          3. 84.(1) This paragraph applies if— (a) there has been a...

        5. Disapplication of section 648

          1. 85.Section 648 (creditor relationships: embedded derivatives which are exactly tracking...

        6. Existing assets representing creditor relationships: contracts for differences

          1. 86.(1) This paragraph applies if section 648 would apply to...

          2. 87.(1) This paragraph applies if— (a) there has been a...

        7. Disapplication of section 658

          1. 88.(1) Section 658 (chargeable gain or allowable loss treated as...

        8. Disapplication of section 661

          1. 89.Section 661 (contract which becomes derivative contract) does not apply...

        9. Disapplication of section 666

          1. 90.Section 666 (allowable loss treated as accruing) does not apply...

        10. Contracts which became derivative contracts on 16 March 2005

          1. 91.(1) This paragraph applies in relation to a company if...

        11. Contracts which became derivative contracts on 28 July 2005

          1. 92.(1) This paragraph applies in relation to a company if...

        12. Plain vanilla contracts which became derivative contracts before 30 December 2006

          1. 93.(1) This paragraph applies if— (a) a company is a...

        13. Issuers of securities with embedded derivatives: deemed options

          1. 94.(1) This paragraph applies if the company mentioned in section...

        14. Contract becoming derivative contract on 12 March 2008

          1. 95.(1) This paragraph applies if a company was, immediately before...

        15. Avoidance relying on continuity of treatment provisions: transactions before 16 May 2008

          1. 96.Section 629 (disapplication of section 625 where transferor party to...

        16. Disposals for consideration not fully recognised by accounting practice: disposals before 16 May 2008

          1. 97.Section 698 (disposals for consideration not fully recognised by accounting...

        17. References to Companies Act 2006

          1. 98.Until section 658 of the Companies Act 2006 (c. 46)...

        18. Repeal of provisions concerning exchange gains and losses from derivative contracts

          1. 99.(1) The following provisions of this Act (which rewrite provisions...

      11. Part 11 Intangible fixed assets

        1. Transactions between related parties

          1. 100.(1) Sub-paragraphs (2) and (3) apply in relation to any...

        2. Continuity: formation of an SE before 1 April 2005

          1. 101.Section 770 (continuity where group includes an SE) does not...

        3. References to Companies Act 2006

          1. 102.Until section 658 of the Companies Act 2006 (c. 46)...

      12. Part 12 Beneficiaries' income from estates in administration

        1. Basic amounts

          1. 103.(1) Sub-paragraph (2) applies if any previous accounting period to...

        2. Income treated as bearing income tax

          1. 104.(1) A sum treated as part of the aggregate income...

      13. Part 13 Relief for share incentive plans

        1. Deduction for contribution to plan trust

          1. 105.Section 989(1)(a) does not apply in relation to a payment...

        2. Award of shares to excluded employee

          1. 106.(1) This paragraph applies if an amount is received by...

      14. Part 14 Other relief for employee share acquisitions

        1. Accounting periods beginning before 1 January 2003

          1. 107.(1) Relief is not available under Part 12 in relation...

        2. Restricted shares not to include shares acquired before 16 April 2003

          1. 108.In Part 12 “restricted shares” does not include shares acquired...

        3. Shares acquired before 16 April 2003 that are subject to forfeiture

          1. 109.(1) Relief under Part 12 is not available in relation...

        4. Meaning of “employment” for times before 16 April 2003

          1. 110.In relation to any time before 16 April 2003, Part...

        5. Relief under Chapters 4 and 5 of Part 12

          1. 111.(1) This paragraph applies for the purposes of Chapters 4...

      15. Part 15 Research and development

        1. Rates of relief

          1. 112.(1) In relation to expenditure incurred before 1 August 2008,...

        2. R&D threshold in section 1050: qualifying Chapter 3 and 4 expenditure

          1. 113.(1) The references in section 1050(3)(b) and (c) to qualifying...

        3. Chapters 3 to 5 of Part 13: expenditure incurred before 1 April 2002

          1. 114.(1) Chapters 3 to 5 of Part 13 do not...

        4. Chapter 7 of Part 13: expenditure incurred before 22 April 2003

          1. 115.(1) Chapter 7 of Part 13 (relief for SMEs and...

        5. Cap on R&D aid under Chapter 2 or 7 of Part 13

          1. 116.For the purposes of any calculation in accordance with section...

        6. Chapter 7 of Part 13: qualifying expenditure on contracted out R&D

          1. 117.(1) Section 1135(4) (time limit for notice of election for...

        7. Small or medium-sized enterprises

          1. 118.(1) In relation to expenditure incurred before 1 August 2008,...

        8. Staffing costs

          1. 119.(1) In its application to expenditure incurred—

          2. 120.In its application to expenditure incurred before 1 August 2008,...

          3. 121.(1) In relation to expenditure incurred before 27 September 2003,...

        9. Expenditure on software or consumable items

          1. 122.(1) In relation to expenditure incurred before 1 April 2004,...

        10. Qualifying expenditure on externally provided workers

          1. 123.(1) In relation to expenditure incurred before 27 September 2003,...

        11. Qualifying expenditure on relevant payments to subjects of clinical trials

          1. 124.(1) In relation to expenditure incurred before 1 August 2008,...

      16. Part 16 Remediation of contaminated land

        1. Part 14: expenditure incurred before 11 May 2001

          1. 125.(1) Part 14 does not apply to expenditure incurred before...

        2. Staffing costs

          1. 126.(1) In its application to expenditure incurred—

      17. Part 17 Film production

        1. Interpretation

          1. 127.The provisions of sections 1181 to 1187 apply for the...

        2. Chapters 2 and 3 of Part 15 to apply only to films that commence principal photography on or after 1 January 2007

          1. 128.Chapters 2 and 3 of Part 15 apply only in...

          2. 129.The references in section 1206 to the functions of the...

        3. Application of Part 15 etc to films that commenced principal photography before 1 January 2007 but were not completed before that date

          1. 130.(1) The Treasury may make provision by regulations for the...

          2. 131.(1) In accordance with Part 1 of this Schedule, the...

        4. Prohibition on double counting

          1. 132.(1) Expenditure is not to be taken into account for...

      18. Part 18 Management expenses

        1. Unpaid remuneration

          1. 133.(1) This paragraph applies for the purposes of section 1249....

      19. Part 19 Unremittable income

        1. Unremittable income that arose in an accounting period ending before 1 April 2009

          1. 134.(1) A claim may be made under section 1275 (claim...

        2. Withdrawal of relief: income that arose in an accounting period ending before 1 October 1993

          1. 135.Section 1277 (income charged on withdrawal of relief after source...

      20. Part 20 General exemptions

        1. Ulster savings certificates

          1. 136.In the case of certificates acquired before 27 July 1981,...

      21. Part 21 Other provisions

        1. Training courses for employees

          1. 137.(1) This paragraph applies if, without the repeal by this...

          2. 138.In the Table in section 98 of TMA 1970 (special...

          3. 139.(1) This paragraph applies if— (a) at any time during...

        2. Unpaid remuneration

          1. 140.(1) This paragraph applies for the purposes of—

        3. Employee benefit contributions

          1. 141.Section 1290 does not apply to deductions that would otherwise...

        4. Interest on overdue corporation tax etc

          1. 142.(1) The repeal by this Act of section 90(1)(b) of...

        5. Miscellaneous profits and losses: apportionment to accounting periods ending before 1 April 2009

          1. 143.(1) This paragraph applies if— (a) a relevant period of...

        6. Purchase and sale of securities: references to setting up and commencement etc of a trade

          1. 144.In section 731 of ICTA, as that section has effect...

        7. References to Companies Act 2006

          1. 145.Until section 658 of the Companies Act 2006 (c. 46)...

        8. Charges to tax under Case VI of Schedule D in subordinate legislation

          1. 146.(1) This paragraph applies if— (a) a provision of the...

          2. 147.(1) This paragraph applies if immediately before 1 April 2009...

    3. SCHEDULE 3

      Repeals and revocations

      1. Part 1 Repeals and revocations on 1 April 2009

      2. Part 2 Prospective repeals

    4. SCHEDULE 4

      Index of defined expressions

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