Please note:
All reference to 'Parts' and 'sections' are from the Corporation Tax Act 2010. For other versions of these Explanatory Notes, see More Resources.
Part 2: Calculation of liability in respect of profits
Chapter 2: Rates at which corporation tax on profits charged
Section 6: UK resident company operating in sterling and preparing accounts in another currency
Section 8: UK resident company preparing accounts in currency other than sterling
Section 9: Non-UK resident company preparing return of accounts in currency other than sterling
Section 10: The equivalent in another currency of a sterling amount
Section 16: Sections 13(2) and 15(5): profit against which carried-forward amount to be set
Section 38: Limit on deduction if accounting period falls partly within 12 month period
Section 39: Terminal losses: extension of periods for which relief may be given
Section 40: Ring fence trades: extension of periods for which relief may be given
Section 41: Sections 39 and 40: transfers of trade to obtain relief
Section 42: Ring fence trades: further extension of period for relief
Section 43: Claim period in case of ring fence or mineral extraction trades
Section 44: Trade must be commercial or carried on for statutory functions
Section 45: Carry forward of trade loss against subsequent trade profits
Section 46: Use of trade-related interest and dividends if insufficient trade profits
Section 54: Non-UK resident company: receipts of interest, dividends or royalties
Chapter 3: Limited partners and members of limited liability partnerships
Section 63: Company with investment business ceasing to carry on UK property business
Section 64: UK property business to be commercial or carried on for statutory functions
Section 65: UK furnished holiday lettings business treated as trade
Section 66: Relief for losses made in overseas property business
Section 67: Overseas property business to be commercial or carried on for statutory functions
Chapter 5: Losses on disposal of shares
Section 72: Limit on deduction if accounting period falls partly within 12 month period
Section 76: Disposal of shares forming part of mixed holding
Section 80: Ceasing to meet trading requirement because of administration etc
Section 87: Relief after an exchange of shares for shares in another company
Chapter 2: Surrender of company’s losses etc for an accounting period
Section 104: Meaning of “non-trading loss on intangible fixed assets”
Section 105: Restriction on surrender of losses etc within section 99(1)(d) to (g)
Section 106: Restriction on losses etc surrenderable by UK resident
Section 107: Restriction on losses etc surrenderable by non-UK resident
Section 109: Restriction on losses etc surrenderable by dual resident
Section 110: Restriction on surrender of losses etc from alternative finance arrangements
Chapter 3: Surrendersmade by non-UK resident company resident or trading in the EEA
Section 113: Steps to determine extent to which loss etc can be surrendered
Section 115: The EEA tax loss condition: companies resident in EEA territory
Section 116: The EEA tax loss condition: companies not resident in EEA territory
Section 118: The qualifying loss condition: relief for current and previous periods
Section 119: The qualifying loss condition: relief for future periods
Section 120: The qualifying loss condition: non-UK tax relief in another territory
Section 122: Assumptions to be made in recalculating EEA amount
Section 124: Assumptions as to places in which activities carried on
Section 127: Amounts excluded because of certain arrangements
Chapter 4: Claims for group relief
Section 130: Group relief claims on amounts surrenderable under Chapter 2
Section 135: Group relief claims on amounts surrenderable under Chapter 3
Section 138: Limitation on amount of group relief applying to all claims
Section 140: Unrelieved part of claimant company’s available total profits
Section 143: Condition 1: surrendering company owned by consortium
Section 144: Condition 1: claimant company owned by consortium
Section 145: Conditions 2 and 3: limitations in sections 143 and 144
Section 146: Conditions 2 and 3: companies in link company’s group
Section 147: Conditions 1 and 2: surrenderable amounts including trading loss
Section 148: Conditions 1 and 2: surrendering company in group of companies
Section 149: Conditions 1 and 3: claimant company in group of companies
Chapter 6: Equity holders and profits or assets available for distribution
Section 163: Normal commercial loans: company’s results or value of assets
Section 165: Proportion of profits available for distribution to which company is entitled
Section 166: Proportion of assets available for distribution to which company is entitled
Section 167: Profits or assets available for distribution and entitlement: supplementary
Section 169: Application and interpretation of sections 170 to 182
Section 172: Company A’s proportion if shares etc have temporary rights
Section 173: Cases in which option arrangements are in place
Section 174: Company A’s proportion if option arrangements in place
Section 178: Cases in which sections 170, 172 and 174 all apply
Section 179: Cases in which surrendering or claimant company is non-UK resident
Section 180: Company A’s proportion if non-UK resident involved
Section 181: Assumptions to be applied if non-UK resident company involved
Chapter 7: Miscellaneous provisions and interpretation of Part
Part 6: Charitable donations relief
Part 7: Community investment tax relief
Chapter 2: Qualifying investments
Chapter 5: Withdrawal or reduction of CITR
Section 244: Disposal of securities or shares during 5 year period
Section 246: Value received by investor during 6 year period: loans
Section 247: Value received by investor during 6 year period: securities or shares
Section 248: Receipts of insignificant value to be added together
Section 251: Value received if there is more than one investment
Chapter 4: Calculation of profits
Section 280: Disposal to be valued by reference to section 2(5A) of OTA 1975
Section 281: Valuation where market value taken into account under section 2 of OTA 1975
Section 282: Valuation where disposal not sale at arm’s length
Section 284: Valuation where relevant appropriation but no disposal
Section 286: Restriction on debits to be brought into account
Section 287: Restriction on credits to be brought into account
Section 289: Reduction of expenditure by reference to regional development grant
Section 290: Adjustment as a result of regional development grant
Section 292: Expenditure on and under abandonment guarantees
Section 293: Relief for reimbursement expenditure under abandonment guarantees
Section 294: Payment under abandonment guarantee not immediately applied
Section 298: Reimbursement by defaulter in respect of certain abandonment expenditure
Section 299: Deduction of PRT in calculating income for corporation tax purposes
Chapter 5: Ring fence expenditure supplement
Section 311: Limit on number of accounting periods for which supplement may be claimed
Section 313: Unrelieved group ring fence profits for accounting periods
Section 314: Taxable ring fence profits for an accounting period
Section 315: Supplement in respect of a pre-commencement accounting period
Section 317: Reduction in respect of disposal receipts under CAA 2001
Section 318: Reduction in respect of unrelieved group ring fence profits
Section 319: The reference amount for a pre-commencement period
Section 321: Supplement in respect of a post-commencement period
Section 322: Amount of post-commencement supplement for a post-commencement period.
Section 325: The pool of ring fence losses and the pool of non-qualifying Schedule 19B losses
Section 327: Reductions in respect of utilised ring fence losses
Section 328: Reductions in respect of unrelieved group ring fence profits
Section 329: The reference amount for a post-commencement period
Chapter 6: Supplementary charge in respect of ring fence trades
Chapter 7: Reduction of supplementary charge for certain new oil fields
Section 335: Carrying part of pool of field allowances into following period
Section 336: Carrying whole of pool of field allowances into following period
Section 338: Holding a field allowance on acquisition of equity share
Section 346: Reduction of field allowance if equity disposed of
Section 347: Acquisition of field allowance if equity acquired
Section 355: “Ultra high pressure/high temperature oil field”
Part 9: Leasing plant or machinery
Chapter 2: Long funding leases of plant or machinery
Section 360: Lessor under long funding finance lease: rental earnings
Section 361: Lessor under long funding finance lease: exceptional items
Section 362: Lessor under long funding finance lease making termination payment
Section 363: Lessor under long funding operating lease: periodic deduction
Section 365: “Starting value” where plantor machinery originally unqualifying
Section 366: Long funding operating lease: lessor’s additional expenditure
Section 369: Lessor under long funding operating lease: termination of lease
Section 371: Adjustments where sections 360 to 369 subsequently disapplied by section 370
Section 372: Lessor also lessee under non–long funding lease
Section 375: Adjustments where sections 360 to 369 subsequently disapplied by section 373
Section 377: Lessee under long funding finance lease: limit on deductions
Section 378: Lessee under long funding finance lease: termination
Chapter 3: Sales of lessors: leasing business carried on by a company alone
Section 383: Income and matching expense in different accounting periods
Section 386: Relief for expense otherwise giving rise to carried forward loss
Section 388: “Relevant plant or machinery value” for condition A in section 387
Section 391: Relevant company’s income for condition B in section 387
Section 395: No qualifying change of ownership in the case of certain intra–group reorganisations
Section 397: Companies owned by consortiums and members of consortiums
Section 402: “PM” where relevant company lessee under long funding lease etc
Section 405: Adjustment to the basic amount: qualifying 75% subsidiaries
Section 406: Adjustment to the basic amount: consortium relationships
Chapter 4: Sales of lessors: leasing business carried on by a company in partnership
Section 411: “Relevant plant or machinery value” for condition A in section 410
Section 413: Relevant plant or machinery value where partnership lessee under long funding lease etc
Section 414: Partnership’s income for condition B in section 410
Section 415: “Qualifying change” in company’s interest in a business
Section 416: Determining the percentage share in the profits or loss of business
Section 417: Partner company’s income and other companies’ matching expense
Section 419: Relief for expense otherwise giving rise to carried forward loss
Section 420: Exception: companies carrying on business ceasing to share in its profits
Section 425: Partner company’s income and matching expense in different accounting periods
Section 428: Relief for expense otherwise giving rise to carried forward loss
Chapter 5: Sales of lessors: anti–avoidance provisions
Section 432: Restrictions on relief for Chapter 3 or 4 expenses: introduction
Section 433: Restrictions applying to the restricted loss amount
Section 435: Disregard of increases and decreases in balance sheet amounts
Section 436: Balance sheet amounts determined on assumption company has no liabilities
Chapter 3: Charge to tax in case of loan to participator
Section 457: Section 456: meaning of “material interest in a company”
Section 462: Determination of particular questions as a result of section 460
Section 463: Taxation of debtor on release of loan to trustees of settlement which has ended
Section 464: Section 463: other person treated as releasing or writing off debt
Part 11: Charitable companies etc
Chapter 2: Gifts and other payments
Section 471: Gifts qualifying for gift aid relief: income tax treated as paid
Section 472: Gifts qualifying for gift aid relief: corporation tax liability and exemption
Section 473: Gifts of money from companies: corporation tax liability and exemption
Section 474: Payments from other charities: corporation tax liability and exemption
Section 475: Gifts qualifying for gift aid relief: income tax treated as paid and exemption
Section 481: Exemption from charges under provisions to which section 1173 applies
Section 482: Condition as to trading and miscellaneous incoming resources
Section 486: Exemption for investment income and non-trading profits from loan relationships
Section 489: Exemption for income from estates in administration
Chapter 4: Restrictions on exemptions
Section 495: How income is attributed to the non-exempt amount
Section 499: Section 496(1)(d): accounting period in which certain expenditure treated as incurred
Section 500: Section 496(1)(d): payment to body outside the UK
Section 501: Section 496(1)(g) and (h): investments and loans
Section 504: Non-charitable expenditure in substantial donor transactions
Section 505: Adjustment if section 504(1) and (2) applied to single transaction
Section 506: Section 504: certain payments and benefits to be ignored
Section 512: Securities which are approved charitable investments
Section 515: Excess expenditure treated as non-charitable expenditure of earlier periods
Section 516: Rules for attributing excess expenditure to earlier periods
Part 12: Real Estate Investment Trusts
Chapter 8: Breach of conditions in Chapter 2
Section 561: Notice of breach of relevant Chapter 2 condition
Section 562: Breach of conditions C and D in section 528 (conditions for company)
Section 563: Breach of conditions as to property rental business
Section 564: Breach of condition as to distribution of profits
Section 566: Breach of condition B in section 531 in accounting period 1
Section 568: Breach of balance of business conditions after accounting period 1
Chapter 9: Leaving the UK REIT regime
Section 572: Termination by notice: officer of Revenue and Customs
Section 575: Notice under section 572: breach of conditions as to property rental business
Section 576: Notice under section 572: breach of conditions as to balance of business
Section 577: Notice under section 572: multiple breaches of conditions in Chapter 2
Section 578: Automatic termination for breach of certain conditions in section 528
Section 584: Meaning of “joint venture company” and “joint venture group”
Section 585: Meaning of “venturing group” and “venturingcompany”
Section 586: Notice for Part to apply: joint venture company
Section 593: Financial statements under section 532: joint venture groups
Section 595: Joint venture company liable for additional charge
Section 596: Member of joint venture group liable for additional charge
Part 13: Other special types of company etc
Chapter 5: Companies in liquidation or administration
Section 626: Meaning of “final year”, “penultimate year” etc
Section 627: Meaning of “rate of corporation tax” in case of companies with small profits
Section 629: Company in liquidation: making of assessment to tax
Section 630: Company in administration: corporation tax rates
Section 631: Company in administration: making of assessment to tax
Section 633: Exemption for interest on overpaid tax in final accounting period
Chapter 9: Community amateur sports clubs
Section 658: Meaning of “community amateur sports club” and “registered club”
Section 661: Meaning of “eligible sport”, “qualifying purposes” etc
Section 666: Exemptions reduced if non-qualifying expenditure incurred
Section 667: Rules for attributing surplus amount to earlier periods etc
Section 669: Asset ceasing to be held for qualifying purposes etc
Part 14: Change in company ownership
Chapter 3: Company with investment business: restrictions on relief: general provision
Section 678: Notional split of accounting period in which change in ownership occurs
Section 679: Restriction on debits to be brought into account
Section 680: Restriction on the carry forward of non-trading deficit from loan relationships
Section 681: Restriction on relief for non-trading loss on intangible fixed assets
Section 682: Restriction on the deduction of expenses of management
Section 684: Disallowance of overseas property business losses
Section 687: Adjustment to balancing charges if relief is restricted
Section 688: Meaning of “significant increase in the amount of a company’s capital”
Chapter 4: Company with investment business: restrictions on relief: asset transferred within group
Section 693: Meaning of “amount of profits which represents a relevant gain”
Section 695: Notional split of accounting period in which change in ownership occurs
Section 696: Restriction on debits to be brought into account
Section 697: Restriction on the carry forward of non-trading deficit from loan relationships
Section 698: Restriction on relief for non-trading loss on intangible fixed assets
Section 699: Restrictions on the deduction of expenses of management
Section 701: Disallowance of overseas property business losses
Chapter 5: Company without investment business: disallowance of property losses
Chapter 6: Recovery of unpaid corporation tax
Section 708: Rights to be attributed for the purposes of section 707
Section 710: Recovery of unpaid corporation tax for accounting period beginning before change
Section 711: Conditions relating to company’s trade or business
Section 712: Meaning of “a major change in the nature or conduct of a trade or business”
Section 713: Recovery of unpaid corporation tax for accounting period ending on or after change
Section 715: Meaning of “transaction entered into in connection with change in ownership”
Section 717: Effect of payment in pursuance of assessment under section 710 or713
Chapter 7: Meaning of “change in the ownership of a company”
Part 17: Manufactured payments and repos
Chapter 5: Stock lending arrangements and repos
Section 808: No tax credits for borrower under stock lending arrangement
Section 809: No tax credits for lender under creditor repo or creditor quasi-repo
Section 810: No tax credits for borrower under debtor repo or debtor quasi-repo
Section 811: Arrangements between companies to make distributions
Section 812: Deemed manufactured payments: stock lending arrangements
Part 19: Sale and lease-back etc
Chapter 1: Payments connected with transferred land
Section 835: Transferor or associate becomes liable for payment of rent
Section 836: Transferor or associate becomes liable for payment other than rent
Section 838: Relevant corporation tax relief: deduction not to exceed commercial rent
Section 839: Deduction under section 76 of ICTA not to exceed commercial rent
Section 844: Commercial rent: comparison with rent under a lease
Section 845: Commercial rent: comparison with payments other than rent
Part 20: Tax avoidance involving leasing plant or machinery
Chapter 1: Restrictions on use of losses in leasing partnerships
Chapter 2: Capital payments in respect of leases treated as income
Section 890: Capital payments in respect of leases treated as income
Section 891: Apportionments for leases of plant or machinery and other property
Section 892: Deduction where failure to make relevant capital payment expected
Section 893: Meaning in Chapter of “Capital payment”, “relevant capital payment” etc
Part 21: Leasing arrangements: finance leases and loans
Chapter 2: Finance leases with return in capital form
Section 904: The arrangements and circumstances referred to in section 902(8)
Section 905: Current lessor taxed by reference to accountancy rental earnings
Sections 906 to 910: Reduction of taxable rent by cumulative rental excesses
Section 906: Reduction of taxable rent by cumulative rental excesses: introduction
Section 907: Meaning of “accountancy rental excess” and “cumulative accountancy rental excess”
Section 908: Reduction of taxable rent by the cumulative accountancy rental excess
Section 909: Meaning of “normal rental excess” and “cumulative normal rental excess”
Section 910: Reduction of taxable rent by the cumulative normal rental excess
Sections 911 to 914: Relief for bad debts by reduction of cumulative rental excesses
Section 911: Relief for bad debts: reduction of cumulative accountancy rental excess
Section 912: Recovery of bad debts following reduction under section 911
Section 913: Relief for bad debts: reduction of cumulative normal rental excess
Section 914: Recovery of bad debts following reduction under section 913
Section 916: Assignments on which neither a gain nor a loss accrues
Sections 917 to 922: Capital allowances: clawback of major lump sums
Section 918: Cases where expenditure taken into account under Part 2, 5 or 8 of CAA 2001
Section 919: Cases where expenditure taken into account under other provisions of CAA 2001
Section 920: Capital allowances deductions: waste disposal and cemeteries
Section 923: Pre-26 November 1996 schemes where this Chapter does not at first apply
Section 924: Post-25 November 1996 schemes to which Chapter 3 applied first
Part 22: Miscellaneous provisions
Chapter 1: Transfers of trade without a change of ownership
Section 939: Meaning of “transfer of a trade” and related expressions
Section 942: Options that may be applied for the purposes of the ownership condition
Section 945: Cases in which predecessor retains more liabilities than assets
Section 950: Transfers of trades involving business of leasing plant or machinery
Section 952: Apportionment if part of trade treated as separate trade
Section 953: Application of Chapter to further transfers of a trade
Chapter 2: Transfers of trade to obtain balancing allowances
Chapter 5: Set off of income tax deductions against corporation tax
Chapter 6: Collection etc of tax from UK representatives of non–UK resident companies
Chapter 7: Recovery of unpaid corporation tax due from non–UK resident company
Section 981: Exemption for trade unions and eligible employers’ associations
Section 983: Meaning of “trade union” and “eligible employers’ association”
Section 984: Local authorities and local authority associations
Section 988: Issue departments of the Reserve Bank of India and the State Bank of Pakistan
Part 23: Company distributions
Chapter 2: Matters which are distributions
Section 1001: Provisions related to paragraphs A to H in section 1000(1)
Section 1004: Securities issued otherwise than for new consideration
Section 1006: Distributions exceeding consideration received for issue of security
Section 1007: Securities issued at premium representing new consideration
Section 1008: Consideration for issue of security exceeding amount of principal
Section 1009: Securities reflecting dividends on certain shares etc: exclusion of section 1008
Section 1011: Meaning of “associated company” in section 1009
Section 1020: Transfers of assets or liabilities treated as distributions
Section 1022: Bonus issue following repayment of share capital treated as distribution
Section 1025: Share capital issued at a premium representing new consideration
Section 1027: Cap on amount of distributions affected by section 1026
Section 1028: Certain payments connected with exempt distributions
Chapter 3: Matters which are not distributions
Section 1030: Distribution in respect of share capital in a winding up
Section 1032: Interest etc paid in respect of certain securities
Section 1033: Purchase by unquoted trading company of own shares
Section 1037: Requirement as to reduction of seller’s interest as shareholder
Section 1038: Section 1037: effect of entitlement to profits
Section 1039: Requirements where purchasing company is a member of a group
Section 1040: Determining whether interests as shareholders in a group are substantially reduced
Section 1041: Section 1040: effect of entitlement to profits
Section 1044: Advance clearance of payments by Commissioners
Section 1047: Meaning of “group” and “51% subsidiary” in sections 1033 to 1047
Section 1050: Application of section 1049 where bonus share capital is converted etc
Section 1051: “Bonus share capital” and “in lieu of a cash dividend”
Section 1052: Share capital to which section 1049 applies: returns
Section 1055: Industrial and provident societies: interest and share dividends
Section 1057: UK agricultural or fishing co-operatives: interest and share dividends
Section 1058: Meaning of “UK agricultural or fishing co-operative”
Chapter 4: Special rules for distributions made by certain companies
Section 1064: Certain expenses of close companies treated as distributions
Section 1065: Exception for benefits treated as employment income etc
Section 1066: Exception for certain transfers between UK resident companies
Section 1067: Companies acting in concert or under arrangements
Section 1068: Meaning of “participator” in sections 1064 to 1067
Section 1077: Transfer by distributing company and issue of shares by transferee company
Section 1078: Division of business in a cross-border transfer
Section 1082: Conditions for distributions within section 1076(a)
Section 1083: Conditions for distributions within section 1077
Section 1085: Conditions to be met if the distributing company is a 75% subsidiary
Section 1086: Chargeable payments connected with exempt distributions
Section 1087: Chargeable payments not deductible in calculating profits
Section 1089: Meaning of “chargeable payment”: unquoted companies
Section 1090: Meaning of “company concerned in an exempt distribution”
Section 1093: Requirements relating to applications for clearance
Section 1097: Information about person for whom a payment is received
Chapter 6: Information and returns: further provisions
Section 1100: Qualifying distributions: right to request a statement
Section 1101: Non-qualifying distributions etc: returns and information
Section 1102: Non-qualifying distributions etc: additional information
Section 1103: Power to modify or replace sections 1101 and 1102
Section 1104: Company distributing dividend or interest: duty to provide tax certificates
Section 1108: Alternative means of compliance with sections 1104 and 1105
Part 24: Corporation Tax Acts definitions etc
Part 25: Definitions for purposes of Act and final provisions
Schedule 1: Minor and consequential amendments
Part 1: Income and Corporation Taxes Act 1988
Section 343: Company reconstructions without a change of ownership
Section 513: British Airways Board and National Freight Corporation
Section 768A: Change in ownership: disallowance of carry back of trading losses
Section 768B: Change in ownership of company with investment business: deductions generally
Section 774: Transactions between dealing company and associated company
Section 776: Transactions in land: taxation of capital gains
Schedule 28A: Change in ownership of company with investment business: deductions
Companies (Audit, Investigations and Community Enterprise) Act 2004
Section 151: Losses on disposal of shares: interpretation of Chapter
Sections 346, 348(7), 356, 361, 363, 365, 368, 369 and 373: Community investment tax relief
Section 355: Securities or shares: no claim after disposal or excessive receipts of value
Section 364: Value received by investor during 6 year period: securities or shares
Chapter 6 of Part 13: Avoidance involving leases of plant and machinery
Schedule 2 Part 6: Transitionals and savings: losses on disposal of shares
Section 221A: Sums to which sections 217 to 221 do not apply
Section 520: Provision not at arm’s length: non-deductibility of relevant return
Section 1219: Expenses of management of a company’s investment business
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