Section 52: General deductions
153.This section lays down the general corporation tax rule that for credit relief purposes a company may allocate deductions as it thinks fit. It is based on section 797(3) of ICTA.
154.Section 797(3) of ICTA refers to there being “any deduction to be made for charges on income, expenses of management, expenses payable (within the meaning of section 76(1)) or other amounts which can be deducted from or set against or treated as reducing profits of more than one description”. Subsection (1) refers, more succinctly, to there being “any amount (“the deduction”) that for corporation tax purposes is deductible from, or otherwise allowable against, profits of more than one description”. This compression does not change the law.