Corporation Tax Act 2010 (c. 4)

Part 14 U.K. Change in company ownership

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

Meaning of “significant increase in the amount of a company's capital” U.K.

689 Amount A U.K.

(1) In section 688, amount A is the lower of—

(a) the amount of the company's capital immediately before the change in ownership, and

(b) the highest 60 day minimum amount for the pre-change year.

(2) The highest 60 day minimum amount for the pre-change year is found as follows.

• Step 1 Find the daily amounts of the company's capital over the pre-change year.

• Step 2 Take the highest of the daily amounts.

• Step 3 Find out whether there was in the pre-change year a period of at least 60 days in which there was no daily amount lower than the amount taken.

• Step 4 If there was, the amount taken is the highest 60 day minimum amount for the pre-change year. If there was not, take the next highest of the daily amounts and repeat step 3; and so on, until the highest 60 day minimum amount for the pre-change year is found.

(3) In this section “the pre-change year” means the period of one year ending immediately before the change in ownership.