Section 19: Marginal relief
80.This section is the first of five that set out the rules for marginal relief. It is based on section 13 of ICTA.
81.Two conditions for the reliefare the same as the first two conditions for entitlement to the small profits rate (see the commentary on section 18). But for the purposes of this relief there are two further conditions. The “augmented profits” (defined in section 32) of the company need to fall between:
the “lower limit” (in ICTA, the “lower relevant maximum amount”); and
the “upper limit” (in ICTA, the “upper relevant maximum amount”).
82.The limits are set out in section 24.
83.Finally, if this section is to apply, the company must have no ring fence profits.
84.This section does not include a requirement that the company should make a claim for the relief. See Change 1 in Annex 1.
