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Corporation Tax Act 2010

Status:

This is the original version (as it was originally enacted).

  1. Introductory Text

  2. Part 1 Introduction

    1. 1.Overview of Act

  3. Part 2 Calculation of liability in respect of profits

    1. Chapter 1 Introduction

      1. 2.Overview of Part

    2. Chapter 2 Rates at which corporation tax on profits charged

      1. 3.Corporation tax rates

    3. Chapter 3 Calculation of amount to which rates applied

      1. 4.Amount of profits to which corporation tax rates applied

    4. Chapter 4 Currency

      1. The currency to be used in tax calculations

        1. 5.Basic rule: sterling to be used

        2. 6.UK resident company operating in sterling and preparing accounts in another currency

        3. 7.UK resident company operating in currency other than sterling and preparing accounts in another currency

        4. 8.UK resident company preparing accounts in currency other than sterling

        5. 9.Non-UK resident company preparing return of accounts in currency other than sterling

      2. Translating amounts into other currencies

        1. 10.The equivalent in another currency of a sterling amount

        2. 11.Sterling equivalents: basic rule

        3. 12.Sterling equivalents: carried-back amounts

        4. 13.Sterling equivalents: carried-forward amounts

      3. Adjustment of sterling losses

        1. 14.Carried-back amounts

        2. 15.Carried-forward amounts

      4. Interpretation

        1. 16.Sections 13(2) and 15(5): profit against which carried-forward amount to be set off

        2. 17.Interpretation of Chapter

  4. Part 3 Companies with small profits

    1. The small profits rate

      1. 18.Profits charged at the small profits rate

    2. Marginal relief

      1. 19.Marginal relief

      2. 20.Company with only ring fence profits

      3. 21.Company with ring fence profits and other profits

      4. 22.The ring fence amount

      5. 23.The remaining amount

    3. The lower limit and the upper limit

      1. 24.The lower limit and the upper limit

      2. 25.Associated companies

      3. 26.Section 25(3): treatment of certain non-trading companies

      4. 27.Attribution to persons of rights and powers of their partners

      5. 28.Associated companies: fixed-rate preference shares

      6. 29.Association through a loan creditor

      7. 30.Association through a trustee

    4. Supplementary

      1. 31.Power to obtain information

      2. 32.Meaning of “augmented profits”

      3. 33.Interpretation of section 32(2) and (3)

      4. 34.Close investment-holding companies

  5. Part 4 Loss relief

    1. Chapter 1 Introduction

      1. 35.Overview of Part

    2. Chapter 2 Trade losses

      1. Introduction

        1. 36.Introduction to Chapter

      2. Trade loss relief against total profits

        1. 37.Relief for trade losses against total profits

        2. 38.Limit on deduction if accounting period falls partly within 12 month period

        3. 39.Terminal losses: extension of periods for which relief may be given

        4. 40.Ring fence trades: extension of periods for which relief may be given

        5. 41.Sections 39 and 40: transfers of trade to obtain relief

        6. 42.Ring fence trades: further extension of period for relief

        7. 43.Claim period in case of ring fence or mineral extraction trades

        8. 44.Trade must be commercial or carried on for statutory functions

      3. Carry forward of trade loss relief

        1. 45.Carry forward of trade loss against subsequent trade profits

        2. 46.Use of trade-related interest and dividends if insufficient trade profits

        3. 47.Registered industrial and provident societies

      4. Restrictions on relief: farming or market gardening

        1. 48.Farming or market gardening

        2. 49.Reasonable expectation of profit

        3. 50.Cessation of trades

        4. 51.Companies treated as same person as individual

      5. Restrictions on relief: commodity futures

        1. 52.Dealings in commodity futures

      6. Other restrictions on relief

        1. 53.Leasing contracts and company reconstructions

        2. 54.Non-UK resident company: receipts of interest, dividends or royalties

    3. Chapter 3 Limited partners and members of limited liability partnerships

      1. Introduction

        1. 55.Introduction to Chapter

      2. Limited partners

        1. 56.Restriction on reliefs for limited partners

        2. 57.Meaning of “contribution to the firm”

        3. 58.Meaning of “limited partner”

      3. Members of LLPs

        1. 59.Restriction on relief for members of LLPs

        2. 60.Meaning of “contribution to the LLP

        3. 61.Unrelieved losses brought forward

    4. Chapter 4 Property losses

      1. UK property businesses

        1. 62.Relief for losses made in UK property business

        2. 63.Company with investment business ceasing to carry on UK property business

        3. 64.UK property business to be commercial or carried on for statutory functions

        4. 65.UK furnished holiday lettings business treated as trade

      2. Overseas property businesses

        1. 66.Relief for losses made in overseas property business

        2. 67.Overseas property business to be commercial or carried on for statutory functions

    5. Chapter 5 Losses on disposal of shares

      1. Share loss relief against income

        1. 68.Share loss relief

        2. 69.Eligibility conditions

        3. 70.Entitlement to claim

        4. 71.How relief works

        5. 72.Limit on deduction if accounting period falls partly within 12 month period

      2. Shares: subscription and disposal

        1. 73.Subscription for shares

        2. 74.Disposals of new shares

        3. 75.Limits on relief

        4. 76.Disposal of shares forming part of mixed holding

        5. 77.Section 76: supplementary

      3. Qualifying trading companies: the requirements

        1. 78.Qualifying trading companies

        2. 79.The trading requirement

        3. 80.Ceasing to meet trading requirement because of administration etc

        4. 81.The control and independence requirement

        5. 82.The qualifying subsidiaries requirement

        6. 83.The property managing subsidiaries requirement

        7. 84.The gross assets requirement

        8. 85.The unquoted status requirement

        9. 86.Power to amend requirements by Treasury order

      4. Qualifying trading companies: supplementary

        1. 87.Relief after an exchange of shares for shares in another company

        2. 88.Substitution of new shares for old shares

        3. 89.Deemed time of issue for certain shares

      5. Interpretation

        1. 90.Interpretation of Chapter

    6. Chapter 6 Losses from miscellaneous transactions

      1. 91.Relief for losses from miscellaneous transactions

    7. Chapter 7 Write-off of government investment

      1. 92.Loss relief to be reduced if government investment is written off

      2. 93.Groups of companies

      3. 94.Cases in which government investment is written off

      4. 95.Meaning of “carry-forward losses”

      5. 96.Interaction with other tax provisions

  6. Part 5 Group relief

    1. Chapter 1 Introduction

      1. 97.Introduction to Part

    2. Chapter 2 Surrender of company’s losses etc for an accounting period

      1. Introduction

        1. 98.Overview of Chapter

      2. Basic provisions about surrendering losses and other amounts

        1. 99.Surrendering of losses and other amounts

        2. 100.Meaning of “trading loss”

        3. 101.Meaning of “capital allowance excess”

        4. 102.Meaning of “UK property business loss”

        5. 103.Meaning of “management expenses”

        6. 104.Meaning of “non-trading loss on intangible fixed assets”

      3. Restrictions on losses and other amounts that may be surrendered

        1. 105.Restriction on surrender of losses etc within section 99(1)(d) to (g)

        2. 106.Restriction on losses etc surrenderable by UK resident

        3. 107.Restriction on losses etc surrenderable by non-UK resident

        4. 108.Meaning of “non-UK profits”

        5. 109.Restriction on losses etc surrenderable by dual resident

        6. 110.Restriction on surrender of losses etc from alternative finance arrangements

    3. Chapter 3 Surrenders made by non-UK resident company resident or trading in the EEA

      1. Introduction

        1. 111.Overview of Chapter

        2. 112.EEA related definitions

      2. Basic provisions about surrendering losses and other amounts

        1. 113.Steps to determine extent to which loss etc can be surrendered

      3. Conditions that must be met

        1. 114.The equivalence condition

        2. 115.The EEA tax loss condition: companies resident in EEA territory

        3. 116.The EEA tax loss condition: companies not resident in EEA territory

        4. 117.The qualifying loss condition: general

        5. 118.The qualifying loss condition: relief for current and previous periods

        6. 119.The qualifying loss condition: relief for future periods

        7. 120.The qualifying loss condition: non-UK tax relief in another territory

        8. 121.The precedence condition

      4. Other rules, assumptions and exclusions

        1. 122.Assumptions to be made in recalculating EEA amount

        2. 123.Assumptions as to UK residence

        3. 124.Assumptions as to places in which activities carried on

        4. 125.Assumptions as to accounting periods

        5. 126.Assumptions in relation to capital allowances

        6. 127.Amounts excluded because of certain arrangements

        7. 128.Rules for recalculating EEA amount

    4. Chapter 4 Claims for group relief

      1. Introduction

        1. 129.Overview of Chapter

      2. Surrenderable amounts under Chapter 2

        1. 130.Group relief claims on amounts surrenderable under Chapter 2

        2. 131.The group condition

        3. 132.Consortium condition 1

        4. 133.Consortium conditions 2 and 3

        5. 134.Meaning of “UK related” company

      3. Surrenderable amounts under Chapter 3

        1. 135.Group relief claims on amounts surrenderable under Chapter 3

        2. 136.The EEA group condition

      4. Giving of group relief

        1. 137.Deduction from total profits

      5. General limitation on amount of group relief to be given

        1. 138.Limitation on amount of group relief applying to all claims

        2. 139.Unused part of the surrenderable amounts

        3. 140.Unrelieved part of claimant company’s available total profits

        4. 141.Sections 139 and 140: supplementary

        5. 142.Meaning of “the overlapping period”

      6. Limitations on group relief if claim based on consortium condition 1, 2 or 3

        1. 143.Condition 1: surrendering company owned by consortium

        2. 144.Condition 1: claimant company owned by consortium

        3. 145.Conditions 2 and 3: limitations in sections 143 and 144

        4. 146.Conditions 2 and 3: companies in link company’s group

        5. 147.Conditions 1 and 2: surrenderable amounts including trading loss

        6. 148.Conditions 1 and 2: surrendering company in group of companies

        7. 149.Conditions 1 and 3: claimant company in group of companies

    5. Chapter 5 Subsidiaries, groups and consortiums

      1. Introduction

        1. 150.Overview of Chapter

      2. Explanations of terms

        1. 151.Meaning of “75% subsidiary” and “90% subsidiary”

        2. 152.Groups of companies

        3. 153.Companies owned by consortiums and members of consortiums

      3. Arrangements for transfers of companies

        1. 154.Arrangements for transfer of member of group of companies etc

        2. 155.Arrangements for transfer of company owned by consortium etc

        3. 156.Sections 154 and 155: supplementary

    6. Chapter 6 Equity holders and profits or assets available for distribution

      1. Introduction

        1. 157.Introduction to Chapter

      2. Equity holders

        1. 158.Meaning of “equity holder”

        2. 159.Use of relevant company’s assets

        3. 160.Meaning of “ordinary shares”

        4. 161.Meaning of “restricted right to dividends”

        5. 162.Meaning of “normal commercial loan”

        6. 163.Normal commercial loans: company’s results or value of assets

        7. 164.Sections 160 and 162: supplementary

      3. Company’s entitlement to profits or assets available for distribution: basic provisions

        1. 165.Proportion of profits available for distribution to which company is entitled

        2. 166.Proportion of assets available for distribution to which company is entitled

        3. 167.Profits or assets available for distribution and entitlement: supplementary

        4. 168.Meaning of “the relevant accounting period”

      4. Company’s entitlement to profits or assets available for distribution: supplementary

        1. 169.Application and interpretation of sections 170 to 182

        2. 170.Shares or securities with limited rights

        3. 171.Shares or securities with temporary rights

        4. 172.Company A’s proportion if shares etc have temporary rights

        5. 173.Cases in which option arrangements are in place

        6. 174.Company A’s proportion if option arrangements in place

        7. 175.Cases in which both sections 170 and 172 apply

        8. 176.Cases in which both sections 170 and 174 apply

        9. 177.Cases in which both sections 172 and 174 apply

        10. 178.Cases in which sections 170, 172 and 174 all apply

        11. 179.Cases in which surrendering or claimant company is non-UK resident

        12. 180.Company A’s proportion if non-UK resident involved

        13. 181.Assumptions to be applied if non-UK resident company involved

        14. 182.Assets etc referable to UK trade

    7. Chapter 7 Miscellaneous provisions and interpretation of Part

      1. Miscellaneous

        1. 183.Payments for group relief

        2. 184.References to “allowance” in CAA 2001

      2. Interpretation

        1. 185.“Trading company” and “holding company”

        2. 186.When activities of a company are double taxation exempt

        3. 187.“Non-UK tax”

        4. 188.Other definitions

  7. Part 6 Charitable donations relief

    1. Chapter 1 Nature of relief

      1. 189.Relief for qualifying charitable donations

      2. 190.Qualifying charitable donations: meaning

    2. Chapter 2 Certain payments to charity

      1. Qualifying payments

        1. 191.Qualifying payments

        2. 192.Condition as to repayment

        3. 193.Associated acquisition etc

        4. 194.Distributions

        5. 195.Associated benefits

        6. 196.Associated benefits: meaning

        7. 197.Restrictions on associated benefits

        8. 198.Payments and benefits linked to periods of less than 12 months

      2. Payment attributed to earlier period

        1. 199.Payment attributed to earlier accounting period

      3. Interpretation

        1. 200.Company wholly owned by a charity

        2. 201.Associated persons

        3. 202.“Charity”

    3. Chapter 3 Certain disposals to charity

      1. Amounts treated as qualifying charitable donations

        1. 203.Certain disposals of investments

        2. 204.Meaning of qualifying investment

        3. 205.Meaning of qualifying interest in land

        4. 206.The relievable amount

        5. 207.Incidental costs of making disposal

        6. 208.Consideration

      2. Value of net benefit to charity

        1. 209.Value of net benefit to charity

        2. 210.Market value of qualifying investments

        3. 211.Meaning of “disposal-related obligation”

        4. 212.Meaning and amount of “disposal-related liability”

      3. Special provisions about qualifying interests in land

        1. 213.Certificate required from charity

        2. 214.Qualifying interests in land held jointly

        3. 215.Calculation of relievable amount etc where joint disposal of interest in land

        4. 216.Disqualifying events

      4. Interpretation

        1. 217.“Charity”

  8. Part 7 Community investment tax relief

    1. Chapter 1 Introduction

      1. CITR

        1. 218.Meaning of “CITR”

        2. 219.Eligibility for CITR

        3. 220.Form and amount of CITR

      2. Miscellaneous

        1. 221.Meaning of “making an investment”

        2. 222.Determination of “the invested amount”

        3. 223.Meaning of “the 5 year period” and “the investment date”

        4. 224.Overview of other Chapters of Part

    2. Chapter 2 Qualifying investments

      1. 225.Qualifying investments: introduction

      2. 226.Conditions to be met in relation to loans

      3. 227.Conditions to be met in relation to securities

      4. 228.Conditions to be met in relation to shares

      5. 229.Tax relief certificates

      6. 230.No pre-arranged protection against risks

    3. Chapter 3 General conditions

      1. 231.No control of CDFI by investor

      2. 232.Investor must have beneficial ownership

      3. 233.Investor must not be accredited

      4. 234.No acquisition of share in partnership

      5. 235.No tax avoidance purpose

    4. Chapter 4 Limitations on claims and attribution

      1. Limitations on claims

        1. 236.Loans: no claim after disposal or excessive repayments or receipts of value

        2. 237.Securities or shares: no claim after disposal or excessive receipts of value

        3. 238.No claim after loss of accreditation by the CDFI

        4. 239.Accreditation of investor

      2. Attribution

        1. 240.Attribution: general

        2. 241.Attribution: bonus shares

    5. Chapter 5 Withdrawal or reduction of CITR

      1. Introduction

        1. 242.Introduction to Chapter

      2. Disposals

        1. 243.Disposal of loan during 5 year period

        2. 244.Disposal of securities or shares during 5 year period

      3. Repayment of loans

        1. 245.Repayment of loan capital during 5 year period

      4. Receipts of value

        1. 246.Value received by investor during 6 year period: loans

        2. 247.Value received by investor during 6 year period: securities or shares

        3. 248.Receipts of insignificant value to be added together

        4. 249.When value is received

        5. 250.The amount of value received

        6. 251.Value received if there is more than one investment

        7. 252.Effect of receipt of value on future claims

        8. 253.Receipts of value by or from connected persons

      5. CITR not due

        1. 254.CITR subsequently found not to have been due

      6. Manner of withdrawal or reduction

        1. 255.Manner of withdrawal or reduction of CITR

    6. Chapter 6 Supplementary and general

      1. Alternative finance arrangements

        1. 256.Meaning of “loan” and “interest”

        2. 257.Purchase and resale arrangements

        3. 258.Deposit arrangements

        4. 259.Profit share agency arrangements

      2. Miscellaneous

        1. 260.Information to be provided by the investor

        2. 261.Disclosure

        3. 262.Nominees

        4. 263.Application for postponement of tax pending appeal

        5. 264.Identification of securities or shares on a disposal

      3. Definitions

        1. 265.Meaning of “issue of securities or shares”

        2. 266.Meaning of “disposal”

        3. 267.Construction of references to being “held continuously”

        4. 268.Meaning of “associate”

        5. 269.Minor definitions etc

  9. Part 8 Oil activities

    1. Chapter 1 Introduction

      1. 270.Overview of Part

    2. Chapter 2 Basic definitions

      1. 271.“Associated companies”

      2. 272.“Oil extraction activities”

      3. 273.“Oil rights”

      4. 274.“Oil-related activities”

      5. 275.“Ring fence income”

      6. 276.“Ring fence profits”

      7. 277.“Ring fence trade”

      8. 278.Other definitions

    3. Chapter 3 Deemed separate trade

      1. 279.Oil-related activities treated as separate trade

    4. Chapter 4 Calculation of profits

      1. Oil valuation

        1. 280.Disposal to be valued by reference to section 2(5A) of OTA 1975

        2. 281.Valuation where market value taken into account under section 2 of OTA 1975

        3. 282.Valuation where disposal not sale at arm’s length

        4. 283.Valuation where excess of nominated proceeds

        5. 284.Valuation where relevant appropriation but no disposal

        6. 285.Valuation where appropriation to refining etc

      2. Loan relationships

        1. 286.Restriction on debits to be brought into account

        2. 287.Restriction on credits to be brought into account

      3. Sale and lease-back

        1. 288.Sale and lease-back

      4. Regional development grants

        1. 289.Reduction of expenditure by reference to regional development grant

        2. 290.Adjustment as a result of regional development grant

      5. Tariff receipts etc

        1. 291.Tariff receipts etc

      6. Abandonment guarantees

        1. 292.Expenditure on and under abandonment guarantees

        2. 293.Relief for reimbursement expenditure under abandonment guarantees

        3. 294.Payment under abandonment guarantee not immediately applied

        4. 295.Amounts excluded from section 293(1)

      7. Abandonment expenditure

        1. 296.Introduction to sections 297 and 298

        2. 297.Relief for expenditure incurred by a participator in meeting defaulter’s abandonment expenditure

        3. 298.Reimbursement by defaulter in respect of certain abandonment expenditure

      8. Deduction of PRT in calculating income for corporation tax purposes

        1. 299.Deduction of PRT in calculating income for corporation tax purposes

        2. 300.Effect of repayment of PRT: general rule

        3. 301.Effect of repayment of PRT: special rule

      9. Interest on repayment of PRT or APRT

        1. 302.Interest on repayment of PRT or APRT

      10. Relief

        1. 303.Management expenses

        2. 304.Losses

        3. 305.Group relief

        4. 306.Capital allowances

    5. Chapter 5 Ring fence expenditure supplement

      1. Introduction

        1. 307.Overview of Chapter

      2. Application and interpretation

        1. 308.Qualifying companies

        2. 309.Accounting periods

        3. 310.The relevant percentage

        4. 311.Limit on number of accounting periods for which supplement may be claimed

        5. 312.Qualifying pre-commencement expenditure

        6. 313.Unrelieved group ring fence profits for accounting periods

        7. 314.Taxable ring fence profits for an accounting period

      3. Pre-commencement supplement

        1. 315.Supplement in respect of a pre-commencement accounting period

        2. 316.The mixed pool of qualifying pre-commencement expenditure and supplement previously allowed

        3. 317.Reduction in respect of disposal receipts under CAA 2001

        4. 318.Reduction in respect of unrelieved group ring fence profits

        5. 319.The reference amount for a pre-commencement period

        6. 320.Claims for pre-commencement supplement

      4. Post-commencement supplement

        1. 321.Supplement in respect of a post-commencement period

        2. 322.Amount of post-commencement supplement for a post-commencement period

        3. 323.Ring fence losses

        4. 324.Special rule for straddling periods

        5. 325.The pool of ring fence losses and the pool of non-qualifying Schedule 19B losses

        6. 326.The ring fence pool

        7. 327.Reductions in respect of utilised ring fence losses

        8. 328.Reductions in respect of unrelieved group ring fence profits

        9. 329.The reference amount for a post-commencement period

    6. Chapter 6 Supplementary charge in respect of ring fence trades

      1. 330.Supplementary charge in respect of ring fence trades

      2. 331.Meaning of “financing costs” etc

      3. 332.Assessment, recovery and postponement of supplementary charge

    7. Chapter 7 Reduction of supplementary charge for certain new oil fields

      1. Reduction of adjusted ring fence profits

        1. 333.Reduction of adjusted ring fence profits

      2. Pool of field allowances

        1. 334.Company’s pool of field allowances

        2. 335.Carrying part of pool of field allowances into following period

        3. 336.Carrying whole of pool of field allowances into following period

      3. Field allowance: when held and unactivated amount

        1. 337.Initial licensee to hold a field allowance

        2. 338.Holding a field allowance on acquisition of equity share

        3. 339.Unactivated amount of field allowance

      4. No change in equity share: activation of allowance

        1. 340.Introduction to section 341

        2. 341.Activation of field allowance

      5. Change in equity share: activation of allowance

        1. 342.Introduction to sections 343 and 344

        2. 343.Reference periods

        3. 344.Activation of field allowance

      6. Change in equity share: transfer of field allowance

        1. 345.Introduction to sections 346 and 347

        2. 346.Reduction of field allowance if equity disposed of

        3. 347.Acquisition of field allowance if equity acquired

      7. Miscellaneous

        1. 348.Adjustments

        2. 349.Orders

      8. Interpretation

        1. 350.“New oil field”

        2. 351.“Authorisation of development of an oil field”

        3. 352.“Qualifying oil field”

        4. 353.“Small oil field”

        5. 354.“Ultra heavy oil field”

        6. 355.“Ultra high pressure/high temperature oil field”

        7. 356.“Total field allowance for a new oil field”

        8. 357.Other definitions

  10. Part 9 Leasing plant or machinery

    1. Chapter 1 Introduction

      1. 358.Introduction to Part

    2. Chapter 2 Long funding leases of plant or machinery

      1. Introduction

        1. 359.Overview of Chapter

      2. Lessors under long funding finance leases

        1. 360.Lessor under long funding finance lease: rental earnings

        2. 361.Lessor under long funding finance lease: exceptional items

        3. 362.Lessor under long funding finance lease making termination payment

      3. Lessors under long funding operating leases

        1. 363.Lessor under long funding operating lease: periodic deduction

        2. 364.“Starting value”: general

        3. 365.“Starting value” where plant or machinery originally unqualifying

        4. 366.Long funding operating lease: lessor’s additional expenditure

        5. 367.Determination of remaining residual value resulting from lessor’s first additional expenditure

        6. 368.Determination of remaining residual value resulting from lessor’s further additional expenditure

        7. 369.Lessor under long funding operating lease: termination of lease

      4. Cases where sections 360 to 369 do not apply

        1. 370.Plant or machinery held as trading stock

        2. 371.Adjustments where sections 360 to 369 subsequently disapplied by section 370

        3. 372.Lessor also lessee under non-long funding lease

        4. 373.Other avoidance

        5. 374.Provision supplementing section 373

        6. 375.Adjustments where sections 360 to 369 subsequently disapplied by section 373

        7. 376.Films

      5. Lessees under long funding finance leases

        1. 377.Lessee under long funding finance lease: limit on deductions

        2. 378.Lessee under long funding finance lease: termination

      6. Lessees under long funding operating leases

        1. 379.Lessee under long funding operating lease

        2. 380.“Starting value” in section 379

      7. Interpretation

        1. 381.Interpretation of Chapter

    3. Chapter 3 Sales of lessors: leasing business carried on by a company alone

      1. Introduction

        1. 382.Introduction to Chapter

      2. Income and matching expense in different accounting periods

        1. 383.Income and matching expense in different accounting periods

        2. 384.Amount of income and expense

        3. 385.No carry back of the expense

        4. 386.Relief for expense otherwise giving rise to carried forward loss

      3. “Business of leasing plant or machinery”

        1. 387.“Business of leasing plant or machinery”

        2. 388.“Relevant plant or machinery value” for condition A in section 387

        3. 389.Provision supplementing section 388

        4. 390.Relevant plant or machinery value where relevant company lessee under long funding lease etc

        5. 391.Relevant company’s income for condition B in section 387

      4. “Qualifying change of ownership”

        1. 392.“Qualifying change of ownership”

        2. 393.Qualifying 75% subsidiaries

        3. 394.Consortium relationships

        4. 395.No qualifying change of ownership in certain intra-group reorganisations

        5. 396.No qualifying change of ownership where principal company’s interest in consortium company unchanged

        6. 397.Companies owned by consortiums and members of consortiums

        7. 398.“Qualifying 75% or 90% subsidiary” etc

      5. The amount of the income

        1. 399.The amount of the income: the basic amount

        2. 400.“PM” in section 399

        3. 401.Provisions supplementing section 400

        4. 402.“PM” where relevant company lessee under long funding lease etc

        5. 403.“TWDV” in section 399

        6. 404.Amount to be nil if basic amount negative

        7. 405.Adjustment to the basic amount: qualifying 75% subsidiaries

        8. 406.Adjustment to the basic amount: consortium relationships

        9. 407.Migration

      6. “Associated company”

        1. 408.“Associated company”

    4. Chapter 4 Sales of lessors: leasing business carried on by a company in partnership

      1. Introduction

        1. 409.Introduction to Chapter

      2. “Business of leasing plant or machinery”

        1. 410.“Business of leasing plant or machinery”

        2. 411.“Relevant plant or machinery value” for condition A in section 410

        3. 412.Provision supplementing section 411

        4. 413.Relevant plant or machinery value where partnership lessee under long funding lease etc

        5. 414.Partnership’s income for condition B in section 410

      3. “Qualifying change” in company’s interest in a business

        1. 415.“Qualifying change” in company’s interest in a business

        2. 416.Determining the percentage share in the profits or loss of business

      4. Qualifying changes in partner company’s interest in business

        1. 417.Partner company’s income and other companies’ matching expense

        2. 418.Amount of income and expense

        3. 419.Relief for expense otherwise giving rise to carried forward loss

        4. 420.Exception: companies carrying on business ceasing to share in its profits

        5. 421.The amount of the income: the basic amount

        6. 422.Amount to be nil if basic amount negative

        7. 423.Adjustment to the basic amount

        8. 424.The amount of expense

      5. Qualifying changes of ownership in relation to partner company

        1. 425.Partner company’s income and matching expense in different accounting periods

        2. 426.Amount of income and expense

        3. 427.No carry back of the expense

        4. 428.Relief for expense otherwise giving rise to carried forward loss

        5. 429.The amount of the income

      6. Interpretation

        1. 430.“Associated company”

        2. 431.“Profits” and “loss”

    5. Chapter 5 Sales of lessors: anti-avoidance provisions

      1. 432.Restrictions on relief for Chapter 3 or 4 expenses: introduction

      2. 433.Restrictions applying to the restricted loss amount

      3. 434.Introduction to sections 435 and 436

      4. 435.Disregard of increases and decreases in balance sheet amounts

      5. 436.Balance sheet amounts determined on assumption company has no liabilities

    6. Chapter 6 Sales of lessors: general interpretation

      1. 437.Interpretation of the sales of lessors Chapters

  11. Part 10 Close companies

    1. Chapter 1 Overview of Part

      1. 438.Overview of Part

    2. Chapter 2 Basic definitions

      1. Meaning of “close company": general

        1. 439.“Close company”

        2. 440.Basis of winding up under section 439(3)

        3. 441.Treatment of some persons as participators or directors for the purposes of section 439(3)

      2. Companies which are not to be close companies

        1. 442.Particular types of company

        2. 443.Companies controlled by or on behalf of Crown

        3. 444.Companies involved with non-close companies

        4. 445.Section 444: registered pension schemes

        5. 446.Particular types of quoted company

        6. 447.Section 446: meaning of “shares beneficially held by the public” etc

      3. Meaning of other expressions in this Part

        1. 448.“Associate”

        2. 449.“Associated company”

        3. 450.“Control”

        4. 451.Section 450: rights to be attributed etc

        5. 452.“Director”

        6. 453.“Loan creditor”

        7. 454.“Participator”

    3. Chapter 3 Charge to tax in case of loan to participator

      1. Charge to tax in case of loan to participator

        1. 455.Charge to tax in case of loan to participator

      2. Exceptions to the charge to tax under section 455

        1. 456.Exceptions to the charge under section 455

        2. 457.Section 456: meaning of “material interest in a company”

      3. Relief in case of repayment or release of loan

        1. 458.Relief in case of repayment or release of loan

      4. Loan treated as made to participator

        1. 459.Loan treated as made to participator

      5. Loan treated as made by close company

        1. 460.Loan treated as made by close company

        2. 461.Exception to section 460

        3. 462.Determination of particular questions as a result of section 460

      6. Taxation of debtor on release of loan to trustees of settlement which has ended

        1. 463.Taxation of debtor on release of loan to trustees of settlement which has ended

        2. 464.Section 463: other person treated as releasing or writing off debt

    4. Chapter 4 Power to obtain information

      1. 465.Power to obtain information

  12. Part 11 Charitable companies etc

    1. Chapter 1 Introduction

      1. 466.Overview of Part

      2. 467.Meaning of “charitable company”

      3. 468.Meaning of “eligible body”

      4. 469.Conditions for qualifying as a scientific research association

      5. 470.Meaning of “research and development” in section 469

    2. Chapter 2 Gifts and other payments

      1. Gifts and other payments to charitable companies

        1. 471.Gifts qualifying for gift aid relief: income tax treated as paid

        2. 472.Gifts qualifying for gift aid relief: corporation tax liability and exemption

        3. 473.Gifts of money from companies: corporation tax liability and exemption

        4. 474.Payments from other charities: corporation tax liability and exemption

      2. Gifts to eligible bodies

        1. 475.Gifts qualifying for gift aid relief: income tax treated as paid and exemption

        2. 476.Gifts of money from companies: exemption

      3. Gifts to scientific research associations

        1. 477.Gifts of money from companies: exemption

    3. Chapter 3 Other exemptions

      1. Exemptions

        1. 478.Exemption for profits etc of charitable trades

        2. 479.Meaning of “charitable trade”

        3. 480.Exemption for profits of small-scale trades

        4. 481.Exemption from charges under provisions to which section 1173 applies

        5. 482.Condition as to trading and miscellaneous incoming resources

        6. 483.Exemption for profits from fund-raising events

        7. 484.Exemption for profits from lotteries

        8. 485.Exemption for property income etc

        9. 486.Exemption for investment income and non-trading profits from loan relationships

        10. 487.Exemption for public revenue dividends

        11. 488.Exemption for certain miscellaneous income

        12. 489.Exemption for income from estates in administration

      2. Application of exemptions to certain bodies

        1. 490.Eligible bodies

        2. 491.Scientific research associations

    4. Chapter 4 Restrictions on exemptions

      1. Restrictions on exemptions

        1. 492.Restrictions on exemptions

        2. 493.The non-exempt amount

        3. 494.Attributing income to the non-exempt amount

        4. 495.How income is attributed to the non-exempt amount

      2. Non-charitable expenditure

        1. 496.Meaning of “non-charitable expenditure”

        2. 497.Section 496: supplementary

        3. 498.Section 496(1)(d): meaning of expenditure

        4. 499.Section 496(1)(d): accounting period in which certain expenditure treated as incurred

        5. 500.Section 496(1)(d): payment to body outside the UK

        6. 501.Section 496(1)(g) and (h): investments and loans

      3. Substantial donor transactions

        1. 502.Transactions with substantial donors

        2. 503.Meaning of “relievable gift”

        3. 504.Non-charitable expenditure in substantial donor transactions

        4. 505.Adjustment if section 504(1) and (2) applied to single transaction

        5. 506.Section 504: certain payments and benefits to be ignored

        6. 507.Transactions: exceptions

        7. 508.Donors: exceptions

        8. 509.Connected charities

        9. 510.Substantial donor transactions: supplementary

      4. Approved charitable investments and loans

        1. 511.Approved charitable investments

        2. 512.Securities which are approved charitable investments

        3. 513.Conditions to be met for some securities

        4. 514.Approved charitable loans

      5. Carry back of excess non-charitable expenditure

        1. 515.Excess expenditure treated as non-charitable expenditure of earlier periods

        2. 516.Rules for attributing excess expenditure to earlier periods

        3. 517.Adjustments in consequence of section 515

  13. Part 12 Real Estate Investment Trusts

    1. Chapter 1 Introduction

      1. Introductory

        1. 518.Introduction to Part

      2. Key concepts

        1. 519.“Property rental business”

        2. 520.“UK property rental business” of non-UK companies

        3. 521.“UK company” and “non-UK company”

        4. 522.“Residual business”

    2. Chapter 2 Requirements for being a UK REIT

      1. Becoming a UK REIT

        1. 523.Notice for a group of companies to become a UK REIT

        2. 524.Notice for a company to become a UK REIT

        3. 525.Notice under section 523 or 524: supplementary

        4. 526.Duration of status as UK REIT

      2. Being a UK REIT in relation to an accounting period

        1. 527.Being a UK REIT in relation to an accounting period

        2. 528.Conditions for company

        3. 529.Conditions as to property rental business

        4. 530.Condition as to distribution of profits

        5. 531.Conditions as to balance of business

        6. 532.Financial statements for group UK REITs

        7. 533.Financial statements: supplementary

    3. Chapter 3 Tax treatment of profits and gains of UK REITs

      1. 534.Profits

      2. 535.Gains

    4. Chapter 4 Entering the UK REIT regime

      1. 536.Effects of entry: corporation tax

      2. 537.Effects of entry: CAA 2001

      3. 538.Entry charge

      4. 539.Calculation of the notional amount

      5. 540.Election to treat notional income as arising in instalments

    5. Chapter 5 Assets etc

      1. Ring-fencing of property rental business

        1. 541.Ring-fencing of property rental business

        2. 542.Disapplication of certain provisions

      2. Profits: financing-cost ratio

        1. 543.Profit: financing-cost ratio

        2. 544.Meaning of “property profits” and “property financing costs”

      3. Cancellation of tax advantage

        1. 545.Cancellation of tax advantage

        2. 546.Appeal against notice under section 545

      4. Funds awaiting reinvestment

        1. 547.Funds awaiting reinvestment

    6. Chapter 6 Distributions

      1. Recipients of distributions

        1. 548.Distributions: liability to tax

        2. 549.Distributions: supplementary

      2. Attribution of distributions

        1. 550.Attribution of distributions

      3. Distributions to certain shareholders

        1. 551.Tax consequences of distribution to holder of excessive rights

        2. 552.“The section 552 amount”

        3. 553.Meaning of “holder of excessive rights”

        4. 554.Regulations: distributions to holders of excessive rights

    7. Chapter 7 Gains etc

      1. Movement of assets

        1. 555.Assets: change of use

        2. 556.Disposal of assets

        3. 557.Movement of assets into ring fence

      2. Demergers

        1. 558.Demergers: disposal of asset

        2. 559.Demergers: company leaving group UK REIT

      3. Interpretation

        1. 560.Interpretation of Chapter

    8. Chapter 8 Breach of conditions in Chapter 2

      1. 561.Notice of breach of relevant Chapter 2 condition

      2. 562.Breach of conditions C and D in section 528 (conditions for company)

      3. 563.Breach of conditions as to property rental business

      4. 564.Breach of condition as to distribution of profits

      5. 565.“The section 565 amount”

      6. 566.Breach of condition B in section 531 in accounting period 1

      7. 567.Meaning of “the notional amount”

      8. 568.Breach of balance of business conditions after accounting period 1

      9. 569.Chapter subject to section 572

    9. Chapter 9 Leaving the UK REIT regime

      1. Introduction

        1. 570.Overview of Chapter

      2. Notice to leave regime

        1. 571.Termination by notice: group or company

        2. 572.Termination by notice: officer of Revenue and Customs

        3. 573.Notice under section 572: tax advantage

        4. 574.Notice under section 572: serious breach

        5. 575.Notice under section 572: breach of conditions as to property rental business

        6. 576.Notice under section 572: breach of conditions as to balance of business

        7. 577.Notice under section 572: multiple breaches of conditions in Chapter 2

      3. Automatic termination

        1. 578.Automatic termination for breach of certain conditions in section 528

      4. Effects of cessation

        1. 579.Effects of cessation: corporation tax

        2. 580.Effects of cessation: CAA 2001

      5. Early exit

        1. 581.Early exit by notice

        2. 582.Early exit

    10. Chapter 10 Joint ventures

      1. Introduction

        1. 583.Overview of Chapter

        2. 584.Meaning of “joint venture company” and “joint venture group”

        3. 585.Meaning of “venturing group” and “venturing company”

      2. Notice for Part to apply to joint venture

        1. 586.Notice for Part to apply: joint venture company

        2. 587.Notice for Part to apply: joint venture group

      3. Effect and duration of notice

        1. 588.Effect of notice under section 586

        2. 589.Effect of notice under section 587

        3. 590.Duration of notice under section 586 or 587

      4. Specific requirements and modifications

        1. 591.Conditions as to balance of business

        2. 592.Joint venture groups: financial statements

        3. 593.Financial statements under section 532: joint venture groups

        4. 594.Modifications of Chapter 3

      5. Additional entry charge due in some cases

        1. 595.Joint venture company liable for additional charge

        2. 596.Member of joint venture group liable for additional charge

        3. 597.Cases where no additional charge due

      6. Supplementary

        1. 598.Chapter 10: supplementary

    11. Chapter 11 Part 12: supplementary

      1. Miscellaneous

        1. 599.Calculation of profits

        2. 600.Power to make regulations about cases involving related persons

        3. 601.Availability of group reliefs

        4. 602.Effect of deemed disposal and reacquisition

        5. 603.Regulations

      2. Interpretation

        1. 604.Property rental business: exclusion of listed business

        2. 605.Property rental business: exclusion of business producing listed income

        3. 606.Groups

        4. 607.Meaning of “entry” and “cessation” etc

        5. 608.References to assets

        6. 609.Definitions

  14. Part 13 Other special types of company etc

    1. Chapter 1 Corporate beneficiaries under trusts

      1. Discretionary payments

        1. 610.Discretionary payments by trustees to companies

      2. Trustees’ expenses

        1. 611.Income tax provisions to apply in relation to trustees’ expenses

    2. Chapter 2 Authorised investment funds

      1. Introduction

        1. 612.Overview of Chapter

      2. Open-ended investment companies

        1. 613.Meaning of “open-ended investment company”

        2. 614.Applicable corporation tax rate

        3. 615.Umbrella companies

      3. Authorised unit trusts

        1. 616.Meaning of “authorised unit trust” and “unit holder”

        2. 617.Authorised unit trust treated as UK resident company

        3. 618.Applicable corporation tax rate

        4. 619.Umbrella schemes

      4. Court investment funds

        1. 620.Court investment funds

    3. Chapter 3 Unauthorised unit trusts

      1. 621.Treatment of income

      2. 622.Treatment of capital expenditure

    4. Chapter 4 Securitisation companies

      1. 623.Meaning of “securitisation company”

      2. 624.Power to make regulations about the taxation of securitisation companies

      3. 625.Regulations: supplementary

    5. Chapter 5 Companies in liquidation or administration

      1. Introduction

        1. 626.Meaning of “final year”, “penultimate year” etc

        2. 627.Meaning of “rate of corporation tax” in case of companies with small profits

      2. Companies in liquidation

        1. 628.Company in liquidation: corporation tax rates

        2. 629.Company in liquidation: making of assessment to tax

      3. Companies in administration

        1. 630.Company in administration: corporation tax rates

        2. 631.Company in administration: making of assessment to tax

      4. Supplementary

        1. 632.Meaning of rate being “fixed” or “proposed”

        2. 633.Exemption for interest on overpaid tax in final accounting period

    6. Chapter 6 Banks etc in compulsory liquidation

      1. 634.Overview of Chapter

      2. 635.Application of Chapter

      3. 636.Charge to corporation tax on winding up receipts

      4. 637.Transfer of rights to payment

      5. 638.Allowable deductions

      6. 639.Election to carry back

      7. 640.Relationship of Chapter with other corporation tax provisions

      8. 641.Interpretation of Chapter

    7. Chapter 7 Co-operative housing associations

      1. 642.Disregard of rent from members and of interest payable

      2. 643.Exemption for gains on a sale of property

      3. 644.Approval of housing associations

      4. 645.Tests to be satisfied by the association

      5. 646.Delegation of powers to the Regulator of Social Housing

      6. 647.Claims under section 642 or 643

      7. 648.Adjustments of liability

      8. 649.Power to make further provision

    8. Chapter 8 Self-build societies

      1. 650.Meaning of “self-build society”

      2. 651.Disregard of rent from members

      3. 652.Exemption for gains on disposals of land to members

      4. 653.Approval of self-build societies

      5. 654.Delegation of powers to the Regulator of Social Housing

      6. 655.Claims under section 651 or 652

      7. 656.Adjustments of liability

      8. 657.Power to make further provision

    9. Chapter 9 Community amateur sports clubs

      1. Basic concepts

        1. 658.Meaning of “community amateur sports club” and “registered club”

        2. 659.Meaning of “open to the whole community”

        3. 660.Meaning of “organised on an amateur basis”

        4. 661.Meaning of “eligible sport”, “qualifying purposes” etc

      2. Exemptions

        1. 662.Exemption for UK trading income

        2. 663.Exemption for UK property income

        3. 664.Exemption for interest and gift aid income

        4. 665.Exemption for chargeable gains

      3. Restrictions on exemptions

        1. 666.Exemptions reduced if non-qualifying expenditure incurred

        2. 667.Rules for attributing surplus amount to earlier periods etc

        3. 668.How income and gains are attributed

      4. Deemed disposal and acquisition of asset

        1. 669.Asset ceasing to be held for qualifying purposes etc

      5. Decisions and appeals

        1. 670.Notification of HMRC decision

        2. 671.Appeals

  15. Part 14 Change in company ownership

    1. Chapter 1 Introduction

      1. 672.Overview of Part

    2. Chapter 2 Disallowance of trading losses

      1. 673.Introduction to Chapter

      2. 674.Disallowance of trading losses

      3. 675.Disallowance of trading losses: calculation of balancing charges

      4. 676.Disallowance of trading losses where company reconstruction without change in ownership

    3. Chapter 3 Company with investment business: restrictions on relief: general provision

      1. Introduction

        1. 677.Introduction to Chapter

      2. Notional split of accounting period in which change in ownership occurs

        1. 678.Notional split of accounting period in which change in ownership occurs

      3. Restrictions on relief

        1. 679.Restriction on debits to be brought into account

        2. 680.Restriction on the carry forward of non-trading deficit from loan relationships

        3. 681.Restriction on relief for non-trading loss on intangible fixed assets

        4. 682.Restriction on the deduction of expenses of management

        5. 683.Disallowance of UK property business losses

        6. 684.Disallowance of overseas property business losses

      4. Apportionment of amounts

        1. 685.Apportionment of amounts

        2. 686.Meaning of certain expressions in section 685

      5. Adjustment to balancing charges if relief is restricted

        1. 687.Adjustment to balancing charges if relief is restricted

      6. Meaning of “significant increase in the amount of a company’s capital”

        1. 688.Meaning of “significant increase in the amount of a company’s capital”

        2. 689.Amount A

        3. 690.Amount B

        4. 691.Meaning of “amount of capital”

    4. Chapter 4 Company with investment business: restrictions on relief: asset transferred within group

      1. Introduction

        1. 692.Introduction to Chapter

        2. 693.Meaning of “amount of profits which represents a relevant gain”

        3. 694.Meaning of “the relevant provisions”

      2. Notional split of accounting period in which change in ownership occurs

        1. 695.Notional split of accounting period in which change in ownership occurs

      3. Restrictions on relief

        1. 696.Restriction on debits to be brought into account

        2. 697.Restriction on the carry forward of non-trading deficit from loan relationships

        3. 698.Restriction on relief for non-trading loss on intangible fixed assets

        4. 699.Restrictions on the deduction of expenses of management

        5. 700.Disallowance of UK property business losses

        6. 701.Disallowance of overseas property business losses

      4. Apportionment of amounts

        1. 702.Apportionment of amounts

        2. 703.Meaning of certain expressions in section 702

    5. Chapter 5 Company without investment business: disallowance of property losses

      1. 704.Company carrying on UK property business

      2. 705.Company carrying on overseas property business

    6. Chapter 6 Recovery of unpaid corporation tax

      1. General definitions

        1. 706.Meaning of “linked” person

        2. 707.Meaning of “control”

        3. 708.Rights to be attributed for the purposes of section 707

        4. 709.Meaning of “the relevant period”

      2. Recovery of unpaid corporation tax for accounting period beginning before change

        1. 710.Recovery of unpaid corporation tax for accounting period beginning before change

        2. 711.Conditions relating to company’s trade or business

        3. 712.Meaning of “a major change in the nature or conduct of a trade or business”

      3. Recovery of unpaid corporation tax for accounting period ending on or after change

        1. 713.Recovery of unpaid corporation tax for accounting period ending on or after change

        2. 714.The expectation condition

        3. 715.Meaning of “transaction entered into in connection with change in ownership”

      4. Miscellaneous

        1. 716.Interest

        2. 717.Effect of payment in pursuance of assessment under section 710 or 713

        3. 718.Meaning of “associated company”

    7. Chapter 7 Meaning of “change in the ownership of a company”

      1. Meaning of “change in the ownership of a company”

        1. 719.Meaning of “change in the ownership of a company”

        2. 720.Section 719: supplementary

        3. 721.When things other than ordinary share capital may be taken into account: Chapters 2 to 5

        4. 722.When things other than ordinary share capital may be taken into account: Chapter 6

      2. Changes in indirect ownership

        1. 723.Changes in indirect ownership

      3. Disregard of change in ownership

        1. 724.Disregard of change in company ownership

      4. Supplementary provision

        1. 725.Provision applying for the purposes of Chapters 2 to 5

        2. 726.Interpretation of Chapter

    8. Chapter 8 Supplementary provision

      1. 727.Extended time limit for assessment

      2. 728.Provision of information about ownership of shares etc

      3. 729.Meaning of “company with investment business”

      4. 730.Meaning of “relevant non-trading debit”

  16. Part 15 Transactions in securities

    1. Introduction

      1. 731.Overview of Part

      2. 732.Meaning of “corporation tax advantage”

    2. Company liable to counteraction of corporation tax advantage

      1. 733.Company liable to counteraction of corporation tax advantage

      2. 734.Exception where no tax avoidance object shown

    3. Circumstances in which corporation tax advantages obtained or obtainable

      1. 735.Abnormal dividends used for exemptions or reliefs (circumstance A)

      2. 736.Receipt of consideration representing company’s assets, future receipts or trading stock (circumstance C)

      3. 737.Receipt of consideration in connection with relevant company distribution (circumstance D)

      4. 738.Receipt of assets of relevant company (circumstance E)

      5. 739.Meaning of “relevant company” in sections 737 and 738

      6. 740.Abnormal dividends: general

      7. 741.Abnormal dividends: the excessive return condition

      8. 742.Abnormal dividends: the excessive accrual condition

    4. Procedure for counteraction of corporation tax advantages

      1. 743.Preliminary notification that section 733 may apply

      2. 744.Opposed notifications: statutory declarations

      3. 745.Opposed notifications: determinations by tribunal

      4. 746.Counteraction notices

      5. 747.Timing of assessments in section 738 cases

    5. Clearance procedure

      1. 748.Application for clearance of transactions

      2. 749.Effect of clearance notification under section 748

    6. Appeals

      1. 750.Appeals against counteraction notices

    7. Interpretation

      1. 751.Interpretation of Part

  17. Part 16 Factoring of income etc

    1. Chapter 1 Transfers of income streams

      1. 752.Application of Chapter

      2. 753.Value of transferred income stream treated as income

      3. 754.Exception: amount otherwise taxed

      4. 755.Exception: transfer by way of security

      5. 756.Partnership shares

      6. 757.Interpretation of Chapter

    2. Chapter 2 Finance arrangements

      1. Type 1 arrangements

        1. 758.Type 1 finance arrangement defined

        2. 759.Certain tax consequences not to have effect

        3. 760.Payments treated as borrower’s income

        4. 761.Deemed loan relationship if borrower is a company

        5. 762.Deemed loan relationship if borrower is partnership with corporate member

      2. Type 2 arrangements

        1. 763.Type 2 finance arrangement defined

        2. 764.Relevant change in relation to partnership

        3. 765.Certain tax consequences not to have effect

        4. 766.Deemed loan relationship

      3. Type 3 arrangements

        1. 767.Type 3 finance arrangement defined

        2. 768.Certain tax consequences not to have effect

        3. 769.Deemed loan relationship

      4. Exceptions

        1. 770.Exceptions: preliminary

        2. 771.Exceptions

        3. 772.Exceptions: relevant person

        4. 773.Power to make further exceptions

      5. Supplementary

        1. 774.Accounts

        2. 775.Arrangements

        3. 776.Assets

    3. Chapter 3 Loan or credit transactions

      1. 777.Loan or credit transaction defined

      2. 778.Certain payments treated as interest

      3. 779.Tax charged on income transferred

  18. Part 17 Manufactured payments and repos

    1. Chapter 1 Introduction

      1. 780.Overview of Part

      2. 781.Key definitions

    2. Chapter 2 Manufactured dividends

      1. 782.Meaning of “manufactured dividend”

      2. 783.Treatment of payer of manufactured dividend

      3. 784.Treatment of recipient of manufactured dividend

      4. 785.Treatment of payer: Real Estate Investment Trusts

      5. 786.Treatment of recipient: Real Estate Investment Trusts

      6. 787.Exemption of manufactured dividends

      7. 788.Statements about manufactured dividends

      8. 789.Powers about administrative provisions

    3. Chapter 3 Manufactured overseas dividends

      1. 790.Meaning of “manufactured overseas dividend”

      2. 791.Treatment of payer of manufactured overseas dividend

      3. 792.Company receiving manufactured overseas dividend from UK resident etc

      4. 793.Section 792: amount treated as withheld

      5. 794.Company receiving manufactured overseas dividend from foreign payer

      6. 795.Exemption of manufactured overseas dividends

    4. Chapter 4 Further provision about manufactured payments

      1. Manufactured payments exceeding, or less than, underlying payments

        1. 796.Manufactured dividends: amounts exceeding underlying payments

        2. 797.Manufactured overseas dividends: amounts exceeding underlying payments

        3. 798.Manufactured overseas dividends less than underlying payments

      2. Manufactured payments under arrangements with unallowable purpose

        1. 799.Manufactured payments under arrangements with unallowable purpose

        2. 800.Arrangements with an unallowable purpose

        3. 801.Sections 799 and 800: supplementary

      3. Miscellaneous

        1. 802.Powers about amounts representative of overseas dividends

        2. 803.Power to deal with special cases

        3. 804.Regulation-making powers: general

    5. Chapter 5 Stock lending arrangements and repos

      1. Interpretation

        1. 805.“Stock lending arrangement”

        2. 806.Section 805: supplementary

        3. 807.“Creditor repo”, “creditor quasi-repo”, “debtor repo” and “debtor quasi-repo”

      2. Tax credits: stock lending arrangements and repos

        1. 808.No tax credits for borrower under stock lending arrangement

        2. 809.No tax credits for lender under creditor repo or creditor quasi-repo

        3. 810.No tax credits for borrower under debtor repo or debtor quasi-repo

        4. 811.Arrangements between companies to make distributions

      3. Deemed manufactured payments

        1. 812.Deemed manufactured payments: stock lending arrangements

    6. Chapter 6 Interpretation of Part

      1. 813.The gross amount of a manufactured overseas dividend etc

      2. 814.Other interpretation

  19. Part 18 Transactions in land

    1. Introduction

      1. 815.Introduction to Part

      2. 816.Meaning of disposing of land

      3. 817.Priority of other tax provisions

    2. Charge to tax on gains from transactions in land

      1. 818.Charge to tax on gains from transactions in land

      2. 819.Gains obtained from land disposals in some circumstances

      3. 820.Person obtaining gain

      4. 821.Company chargeable

      5. 822.Method of calculating gain

    3. Further provisions relevant to the charge

      1. 823.Transactions, arrangements, sales and realisations relevant for Part

      2. 824.Tracing value

      3. 825.Meaning of “another person”

      4. 826.Valuations and apportionments

    4. Exemptions

      1. 827.Gain attributable to period before intention to develop formed

      2. 828.Disposals of shares in companies holding land as trading stock

    5. Recovery of tax

      1. 829.Cases where consideration receivable by person not assessed

      2. 830.Certificates of tax paid etc

    6. Clearances and power to obtain information

      1. 831.Clearance procedure

      2. 832.Power to obtain information

    7. Interpretation

      1. 833.Interpretation of Part

  20. Part 19 Sale and lease-back etc

    1. Chapter 1 Payments connected with transferred land

      1. Introduction

        1. 834.Overview of Chapter

      2. Application of the Chapter

        1. 835.Transferor or associate becomes liable for payment of rent

        2. 836.Transferor or associate becomes liable for payment other than rent

        3. 837.Relevant corporation tax relief

      3. Relief (other than for certain insurance company expenses): restriction and carrying forward

        1. 838.Relevant corporation tax relief: deduction not to exceed commercial rent

      4. Insurance company expenses: restriction and carrying forward of relief

        1. 839.Deduction under section 76 of ICTA not to exceed commercial rent

        2. 840.Carrying forward parts of payments

        3. 841.Aggregation and apportionment of payments

        4. 842.Payments made for later periods

      5. Interpretation etc

        1. 843.Exclusion of service charges etc

        2. 844.Commercial rent: comparison with rent under a lease

        3. 845.Commercial rent: comparison with payments other than rent

        4. 846.Lease and rent

        5. 847.Associated persons

        6. 848.Land outside the UK

    2. Chapter 2 New lease of land after assignment or surrender

      1. Introduction

        1. 849.Overview of Chapter

      2. Application of the Chapter

        1. 850.New lease after assignment or surrender

      3. Taxation of consideration

        1. 851.Taxation of consideration

        2. 852.Position where new lease does not include all original property

      4. Relief for rent under new lease

        1. 853.Relief for rent under new lease

      5. New lease treated as ending

        1. 854.New lease treated as ending

        2. 855.Position where rent reduces

        3. 856.Position where lease may be ended

        4. 857.Position where lease may be varied

        5. 858.Lease treated as ending: rentcharge

      6. Lease varied to provide for increased rent

        1. 859.Lease varied to provide for increased rent

      7. Interpretation

        1. 860.Relevant corporation tax relief

        2. 861.Linked persons

        3. 862.Lease, lessee, lessor and rent

    3. Chapter 3 Leased trading assets

      1. Introduction

        1. 863.Overview of Chapter

      2. Application of the Chapter

        1. 864.Leased trading assets

      3. Relief: restriction and carrying forward

        1. 865.Tax deduction not to exceed commercial rent

        2. 866.Long funding finance leases

        3. 867.Commercial rent

      4. Interpretation

        1. 868.Lease

        2. 869.Relevant asset

    4. Chapter 4 Leased assets: capital sums

      1. Introduction

        1. 870.Overview of Chapter

      2. Application of the Chapter

        1. 871.Application of the Chapter

        2. 872.Payment under lease

        3. 873.Sum obtained

      3. Charge to corporation tax

        1. 874.Charge to corporation tax

        2. 875.Hire-purchase agreements

        3. 876.Adjustments where sum obtained before payment made

      4. Obtaining of sum

        1. 877.Sum obtained in respect of interest

        2. 878.Sum obtained in respect of lessee’s interest

        3. 879.Disposal of interest to associate

      5. Apportionment

        1. 880.Apportionment of payments made and of sums obtained

        2. 881.Manner of apportionment

      6. Interpretation

        1. 882.Associates

        2. 883.Capital sum

        3. 884.Lease

        4. 885.Relevant asset

        5. 886.Relevant tax relief

  21. Part 20 Tax avoidance involving leasing plant or machinery

    1. Chapter 1 Restrictions on use of losses in leasing partnerships

      1. 887.When restrictions on leasing partnership losses under this Chapter apply

      2. 888.Restrictions on leasing partnership losses

      3. 889.Interpretation of Chapter

    2. Chapter 2 Capital payments in respect of leases treated as income

      1. 890.Capital payments in respect of leases treated as income

      2. 891.Apportionments for leases of plant or machinery and other property

      3. 892.Deduction where failure to make relevant capital payment expected

      4. 893.Meaning of “capital payment”, “relevant capital payment” etc

      5. 894.Other interpretation of Chapter

  22. Part 21 Leasing arrangements: finance leases and loans

    1. Chapter 1 Introduction

      1. Introduction

        1. 895.Overview of Part

      2. Meaning of expressions about rent

        1. 896.Normal rent

        2. 897.Accountancy rental earnings

        3. 898.Rental earnings

    2. Chapter 2 Finance leases with return in capital form

      1. Introduction

        1. 899.Arrangements to which this Chapter applies

        2. 900.Purposes of this Chapter

      2. Leases to which this Chapter applies

        1. 901.Application of this Chapter

        2. 902.The conditions referred to in section 901(1)

        3. 903.Provisions supplementing section 902

        4. 904.The arrangements and circumstances referred to in section 902(8)

      3. Current lessor taxed by reference to accountancy rental earnings

        1. 905.Current lessor taxed by reference to accountancy rental earnings

      4. Reduction of taxable rent by cumulative rental excesses

        1. 906.Reduction of taxable rent by cumulative rental excesses: introduction

        2. 907.Meaning of “accountancy rental excess” and “cumulative accountancy rental excess”

        3. 908.Reduction of taxable rent by the cumulative accountancy rental excess

        4. 909.Meaning of “normal rental excess” and “cumulative normal rental excess”

        5. 910.Reduction of taxable rent by the cumulative normal rental excess

      5. Relief for bad debts by reduction of cumulative rental excesses

        1. 911.Relief for bad debts: reduction of cumulative accountancy rental excess

        2. 912.Recovery of bad debts following reduction under section 911

        3. 913.Relief for bad debts: reduction of cumulative normal rental excess

        4. 914.Recovery of bad debts following reduction under section 913

      6. Effect of disposals

        1. 915.Effect of disposals of leases: general

        2. 916.Assignments on which neither a gain nor a loss accrues

      7. Capital allowances: clawback of major lump sum

        1. 917.Effect of capital allowances: introduction

        2. 918.Cases where expenditure taken into account under Part 2, 5 or 8 of CAA 2001

        3. 919.Cases where expenditure taken into account under other provisions of CAA 2001

        4. 920.Capital allowances deductions: waste disposal and cemeteries

        5. 921.Capital allowances deductions: films

        6. 922.Contributors to capital expenditure

      8. Schemes to which this Chapter does not at first apply

        1. 923.Pre-26 November 1996 schemes where this Chapter does not at first apply

        2. 924.Post-25 November 1996 schemes to which Chapter 3 applied first

    3. Chapter 3 Other finance leases

      1. Introduction

        1. 925.Introduction to Chapter

        2. 926.Purpose of this Chapter

      2. Current lessor taxed by reference to accountancy rental earnings

        1. 927.Leases to which this Chapter applies

        2. 928.Current lessor taxed by reference to accountancy rental earnings

      3. Application of provisions of Chapter 2 for purposes of this Chapter

        1. 929.Application of provisions of Chapter 2 for purposes of this Chapter

    4. Chapter 4 Supplementary provisions

      1. 930.Pre-26 November 1996 schemes and post-25 November 1996 schemes

      2. 931.Time apportionment where periods of account do not coincide

      3. 932.Periods of account and related periods of account and accounting periods

      4. 933.Connected persons

      5. 934.Assets which represent the leased asset

      6. 935.Parent undertakings and consolidated group accounts

      7. 936.Assessments and adjustments

      8. 937.Interpretation of Part

  23. Part 22 Miscellaneous provisions

    1. Chapter 1 Transfers of trade without a change of ownership

      1. Introduction

        1. 938.Overview of Chapter

        2. 939.Meaning of “transfer of a trade” and related expressions

      2. Transfers to which Chapter applies

        1. 940.Transfers to which Chapter applies

        2. 941.The ownership condition

        3. 942.Options that may be applied for the purposes of the ownership condition

        4. 943.The tax condition

      3. Effect of Chapter in relation to transfers to which it applies

        1. 944.Modified application of Chapter 2 of Part 4

        2. 945.Cases in which predecessor retains more liabilities than assets

        3. 946.Rules for determining “L”

        4. 947.Rules for determining “A”

        5. 948.Modified application of CAA 2001

        6. 949.Dual resident investing companies

        7. 950.Transfers of trades involving business of leasing plant or machinery

      4. Supplementary

        1. 951.Part of trade treated as separate trade

        2. 952.Apportionment if part of trade treated as separate trade

        3. 953.Application of Chapter to further transfers of a trade

    2. Chapter 2 Transfers of trade to obtain balancing allowances

      1. 954.Transfer of activities on complete cessation of trade

      2. 955.Transfer of activities on part cessation of trade

      3. 956.Apportionment if part of trade treated as separate trade

      4. 957.Chapter 2: supplementary

    3. Chapter 3 Transfer of relief within partnerships

      1. 958.Application

      2. 959.Arrangements for transfer of relief

      3. 960.Restrictions on use of reliefs

      4. 961.Non-trading profits and losses

      5. 962.Interpretation of Chapter

    4. Chapter 4 Surrender of tax refund within group

      1. 963.Power to surrender tax refund

      2. 964.Effects of surrender of tax refund

      3. 965.Interest on tax overpaid or underpaid

      4. 966.Payments for surrendered tax refunds

    5. Chapter 5 Set off of income tax deductions against corporation tax

      1. 967.Deductions from payments received by UK resident companies

      2. 968.Deductions from payments received by non-UK resident companies

    6. Chapter 6 Collection etc of tax from UK representatives of non-UK resident companies

      1. 969.Introduction to Chapter

      2. 970.Obligations and liabilities in relation to corporation tax

      3. 971.Exceptions

      4. 972.Interpretation of Chapter

    7. Chapter 7 Recovery of unpaid corporation tax due from non-UK resident company

      1. 973.Introduction to Chapter

      2. 974.Case in which this Chapter applies

      3. 975.Meaning of “the relevant period”

      4. 976.Meaning of “related company”

      5. 977.Notice requiring payment of unpaid tax

      6. 978.Time limit for giving notice

      7. 979.Amount payable in consortium case

      8. 980.Chapter 7: supplementary

    8. Chapter 8 Exemptions

      1. Trade unions and employers’ associations

        1. 981.Exemption for trade unions and eligible employers’ associations

        2. 982.Qualifying income or gains

        3. 983.Meaning of “trade union” and “eligible employers’ association”

      2. Local authorities etc

        1. 984.Local authorities and local authority associations

      3. Health service bodies

        1. 985.Health service bodies

        2. 986.Meaning of “health service body”

        3. 987.NHS foundation trusts

      4. Reserve Bank of India and State Bank of Pakistan

        1. 988.Issue departments of the Reserve Bank of India and the State Bank of Pakistan

      5. Agricultural societies

        1. 989.Agricultural societies

    9. Chapter 9 Other miscellaneous provisions

      1. European Economic Interest Groupings

        1. 990.European Economic Interest Groupings

      2. Harbour reorganisation schemes

        1. 991.Harbour reorganisation schemes: corporation tax

        2. 992.Harbour reorganisation schemes: capital allowances etc

        3. 993.Harbour reorganisation schemes: chargeable gains

        4. 994.Transfer of part of trade

        5. 995.Interpretation of sections 991 to 994

      3. Groups: use of different accounting practices

        1. 996.Use of different accounting practices within a group of companies

  24. Part 23 Company distributions

    1. Chapter 1 Introduction

      1. 997.Overview of Part

    2. Chapter 2 Matters which are distributions

      1. Introduction

        1. 998.Overview of Chapter

        2. 999.Priority of negative rules

      2. Meaning of “distribution”

        1. 1000.Meaning of “distribution”

        2. 1001.Provisions related to paragraphs A to H in section 1000(1)

      3. Distributions, other than dividends, in respect of shares

        1. 1002.Exceptions for certain transfers of assets or liabilities between a company and its members

      4. Redeemable share capital

        1. 1003.Redeemable share capital

      5. Securities issued otherwise than for new consideration

        1. 1004.Securities issued otherwise than for new consideration

      6. Distributions in respect of non-commercial securities

        1. 1005.Meaning of “non-commercial securities”

        2. 1006.Distributions exceeding consideration received for issue of security

        3. 1007.Securities issued at premium representing new consideration

        4. 1008.Consideration for issue of security exceeding amount of principal

      7. Exceptions to section 1008

        1. 1009.Securities reflecting dividends on certain shares etc: exclusion of section 1008

        2. 1010.Meaning of “qualifying index” in section 1009

        3. 1011.Meaning of “associated company” in section 1009

        4. 1012.Hedging arrangements

        5. 1013.Exception to section 1012

        6. 1014.Meaning of “hedging arrangements”

      8. Distributions in respect of special securities

        1. 1015.Meaning of “special securities”

        2. 1016.Meaning of “equity note” in section 1015

        3. 1017.Section 1015: other interpretation

        4. 1018.The principal secured: special securities

        5. 1019.Relevant alternative finance return

      9. Transfers of assets or liabilities treated as distributions

        1. 1020.Transfers of assets or liabilities treated as distributions

        2. 1021.Section 1020: exceptions

      10. Bonus issue following repayment of share capital

        1. 1022.Bonus issue following repayment of share capital treated as distribution

        2. 1023.Exceptions to section 1022(3)

      11. Interpretation of references to repayment of share capital

        1. 1024.Premiums paid on redemption of share capital

        2. 1025.Share capital issued at a premium representing new consideration

        3. 1026.Distributions following a bonus issue

        4. 1027.Cap on amount of distributions affected by section 1026

        5. 1028.Certain payments connected with exempt distributions

    3. Chapter 3 Matters which are not distributions

      1. Introduction

        1. 1029.Overview of Chapter

      2. Distributions in a winding up

        1. 1030.Distribution in respect of share capital in a winding up

      3. Distribution as part of a cross-border merger

        1. 1031.Distribution as part of a cross-border merger

      4. Payments of interest

        1. 1032.Interest etc paid in respect of certain securities

      5. Purchase of own shares

        1. 1033.Purchase by unquoted trading company of own shares

        2. 1034.Requirements as to residence

        3. 1035.Requirement as to period of ownership

        4. 1036.Determining the period of ownership

        5. 1037.Requirement as to reduction of seller’s interest as shareholder

        6. 1038.Section 1037: effect of entitlement to profits

        7. 1039.Requirements where purchasing company is a member of a group

        8. 1040.Determining whether interests as shareholders in a group are substantially reduced

        9. 1041.Section 1040: effect of entitlement to profits

        10. 1042.Other requirements

        11. 1043.Relaxation of requirements in certain cases

      6. Purchase of own shares: supplementary

        1. 1044.Advance clearance of payments by Commissioners

        2. 1045.Advance clearance: supplementary

        3. 1046.Information and returns

        4. 1047.Meaning of “group” and “51% subsidiary” in sections 1033 to 1047

        5. 1048.Sections 1033 to 1047: other interpretation

      7. Stock dividends

        1. 1049.Stock dividends

        2. 1050.Application of section 1049 where bonus share capital is converted etc

        3. 1051.“Bonus share capital” and “in lieu of a cash dividend”

        4. 1052.Share capital to which section 1049 applies: returns

        5. 1053.Return periods

      8. Building society payments

        1. 1054.Building society payments

      9. Industrial and provident society payments

        1. 1055.Industrial and provident societies: interest and share dividends

        2. 1056.Dividend or bonus relating to transactions

      10. Payments made by UK agricultural or fishing co-operatives

        1. 1057.UK agricultural or fishing co-operatives: interest and share dividends

        2. 1058.Meaning of “UK agricultural or fishing co-operative”

      11. Supplementary provisions

        1. 1059.Associated persons

        2. 1060.Associated persons: trustees

        3. 1061.Associated persons: personal representatives

        4. 1062.Connected persons

        5. 1063.Section 1062: supplementary

    4. Chapter 4 Special rules for distributions made by certain companies

      1. Close companies

        1. 1064.Certain expenses of close companies treated as distributions

        2. 1065.Exception for benefits treated as employment income etc

        3. 1066.Exception for certain transfers between UK resident companies

        4. 1067.Companies acting in concert or under arrangements

        5. 1068.Meaning of “participator” in sections 1064 to 1067

        6. 1069.Additional persons treated as participators

      2. Companies carrying on a mutual business

        1. 1070.Companies carrying on a mutual business

      3. Companies not carrying on a business

        1. 1071.Companies not carrying on a business

      4. Members of a 90% group

        1. 1072.Members of a 90% group

    5. Chapter 5 Demergers

      1. Introduction

        1. 1073.Key terms etc

        2. 1074.Purpose of provisions about demergers

      2. Exempt distributions

        1. 1075.Exempt distributions

        2. 1076.Transfer of shares in subsidiaries to members

        3. 1077.Transfer by distributing company and issue of shares by transferee company

        4. 1078.Division of business in a cross-border transfer

        5. 1079.“The distributing company”

        6. 1080.Meaning of “relevant company”

      3. Exemption by virtue of section 1076 or 1077: conditions

        1. 1081.General conditions

        2. 1082.Conditions for distributions within section 1076(a)

        3. 1083.Conditions for distributions within section 1077(1)

        4. 1084.Cases where condition K does not apply

        5. 1085.Conditions to be met if the distributing company is a 75% subsidiary

      4. Chargeable payments

        1. 1086.Chargeable payments connected with exempt distributions

        2. 1087.Chargeable payments not deductible in calculating profits

        3. 1088.Meaning of “chargeable payment”

        4. 1089.Meaning of “chargeable payment”: unquoted companies

        5. 1090.Meaning of “company concerned in an exempt distribution”

      5. Advance clearance

        1. 1091.Advance clearance of distributions

        2. 1092.Advance clearance of payments

        3. 1093.Requirements relating to applications for clearance

        4. 1094.Decision of the Commissioners or tribunal

      6. Information and returns

        1. 1095.Exempt distributions: returns

        2. 1096.Chargeable payments etc: returns

        3. 1097.Information about person for whom a payment is received

      7. Supplementary

        1. 1098.Meaning of “unquoted company”

        2. 1099.Other definitions etc

    6. Chapter 6 Information and returns: further provisions

      1. General duties to provide information

        1. 1100.Qualifying distributions: right to request a statement

        2. 1101.Non-qualifying distributions etc: returns and information

        3. 1102.Non-qualifying distributions etc: additional information

        4. 1103.Power to modify or replace sections 1101 and 1102

      2. Companies and nominees required to provide tax certificates

        1. 1104.Company distributing dividend or interest: duty to provide tax certificates

        2. 1105.Duties of nominees

        3. 1106.Meaning of “tax certificate” etc

        4. 1107.Penalties

        5. 1108.Alternative means of compliance with sections 1104 and 1105

    7. Chapter 7 Tax credits

      1. 1109.Tax credits for certain recipients of exempt qualifying distributions

      2. 1110.Recovery of overpaid tax credit etc

      3. 1111.Section 1110: supplementary

    8. Chapter 8 Interpretation of Part

      1. 1112.Arrangements between companies

      2. 1113.“In respect of shares”

      3. 1114.“In respect of securities”

      4. 1115.“New consideration”

      5. 1116.References to married persons, or civil partners, living together

      6. 1117.Other interpretation

  25. Part 24 Corporation Tax Acts definitions etc

    1. Chapter 1 Definitions

      1. 1118.Introduction to Chapter

      2. 1119.The definitions

      3. 1120.“Bank”

      4. 1121.“Company”

      5. 1122.“Connected” persons

      6. 1123.“Connected” persons: supplementary

      7. 1124.“Control”

      8. 1125.“Farming” and related expressions

      9. 1126.“Franked investment income”

      10. 1127.“Generally accepted accounting practice” and related expressions

      11. 1128.“Grossing up”

      12. 1129.“Hire-purchase agreement”

      13. 1130.“Local authority”

      14. 1131.“Local authority association”

      15. 1132.“Offshore installation”

      16. 1133.Regulations about the meaning of “offshore installation”

      17. 1134.“Oil and gas exploration and appraisal”

      18. 1135.“Property investment LLP”

      19. 1136.“Qualifying distribution”

      20. 1137.“Recognised stock exchange”

      21. 1138.“Research and development”

      22. 1139.“Tax advantage”

      23. 1140.“Unauthorised unit trust”

    2. Chapter 2 Permanent establishments

      1. General

        1. 1141.Permanent establishments of companies

      2. Circumstances where there is no permanent establishment

        1. 1142.Agent of independent status

        2. 1143.Preparatory or auxiliary activities

        3. 1144.Alternative finance arrangements

      3. Brokers

        1. 1145.The independent broker conditions

      4. Investment managers

        1. 1146.The independent investment manager conditions

        2. 1147.Investment managers: the 20% rule

        3. 1148.Section 1147: interpretation

        4. 1149.Application of 20% rule to collective investment schemes

        5. 1150.Meaning of “investment manager” and “investment transaction”

      5. Lloyd’s agents

        1. 1151.Lloyd’s agents

      6. Supplementary

        1. 1152.Investment managers: disregard of certain chargeable profits

        2. 1153.Miscellaneous

    3. Chapter 3 Subsidiaries

      1. 1154.Meaning of “51% subsidiary”, “75% subsidiary” and “90% subsidiary”

      2. 1155.Indirect ownership of ordinary share capital

      3. 1156.Calculation of amounts owned indirectly: main rules

      4. 1157.Adding fractions together

    4. Chapter 4 Investment trusts

      1. 1158.Meaning of “investment trust”

      2. 1159.Conditions for approval

      3. 1160.Calculation of income

      4. 1161.The income retention condition: exceptions

      5. 1162.The 15% holding limit: exceptions

      6. 1163.Basic meaning of “holding in a company”

      7. 1164.More about the meaning of “holding in a company”

      8. 1165.Other interpretation

    5. Chapter 5 Other Corporation Tax Acts provisions

      1. 1166.Scotland

      2. 1167.Sources of income within the charge to corporation tax or income tax

      3. 1168.Payment of dividends

      4. 1169.Settlements and trustees

      5. 1170.Territorial sea of the United Kingdom

      6. 1171.Orders and regulations

      7. 1172.Apportionment to different periods

      8. 1173.Miscellaneous charges

  26. Part 25 Definitions for purposes of Act and final provisions

    1. Definitions for the purposes of Act

      1. 1174.Abbreviated references to Acts

      2. 1175.Claims and elections

      3. 1176.Meaning of “connected” persons and “control”

    2. Final provisions

      1. 1177.Minor and consequential amendments

      2. 1178.Power to make consequential provision

      3. 1179.Power to undo changes

      4. 1180.Transitional provisions and savings

      5. 1181.Repeals and revocations

      6. 1182.Index of defined expressions

      7. 1183.Extent

      8. 1184.Commencement

      9. 1185.Short title

    1. Schedule 1

      Minor and consequential amendments

      1. Part 1 Income and Corporation Taxes Act 1988

      2. Part 2 Other enactments

    2. Schedule 2

      Transitionals and savings etc

      1. Part 1 General provisions

      2. Part 2 Changes in the law

      3. Part 3 Currency

      4. Part 4 Loss relief (other than share loss relief)

      5. Part 5 Losses on disposal of shares

      6. Part 6 Group Relief

      7. Part 7 Charitable donations relief

      8. Part 8 CITR

      9. Part 9 Oil activities

      10. Part 10 Leasing plant or machinery

      11. Part 11 Close companies

      12. Part 12 Charitable companies etc

      13. Part 13 Real Estate Investment Trusts

      14. Part 14 Co-operative housing associations and self-build societies

      15. Part 15 Transactions in securities

      16. Part 16 Factoring of income etc

      17. Part 17 Manufactured payments and repos

      18. Part 18 Sale and lease-back etc

      19. Part 19 Tax avoidance involving leasing plant or machinery

      20. Part 20 Leasing arrangements: finance leases and loans

      21. Part 21 Transfers of trade without a change in ownership

      22. Part 22 Use of different accounting practices within a group

      23. Part 23 Company distributions

      24. Part 24 Corporation Tax Acts definitions etc

    3. Schedule 3

      Repeals and revocations

      1. Part 1 General

      2. Part 2 Repeals and revocations having effect for corporation tax purposes only

    4. Schedule 4

      Index of defined expressions

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