C1C2C3C4Part 4Transfer pricing

Annotations:
Modifications etc. (not altering text)
C1

Pt. 4 excluded by 2010 c. 4, s. 938N (as inserted (19.7.2011) by Finance Act 2011 (c. 11), Sch. 5 para. 2)

C4

Pt. 4 excluded (with effect in accordance with s. 148 of the amending Act) by Finance Act 2012 (c. 14), s. 129(11) (with s. 147, Sch. 17)

C5CHAPTER 6Balancing payments

Annotations:
Modifications etc. (not altering text)
C5

Pt. 4 Chs. 1 and 3-6 applied (1.4.2022 in relation to accounting periods beginning on or after that date) by Finance Act 2022 (c. 3), s. 51(1), Sch. 9 paras. 3, 4

198Balancing payments by guarantor to issuer: no charge to, or relief from, tax

1

If each of the qualifying conditions (see section 197) is met, subsection (2) applies to the balancing payments made by all of the guarantor companies if, or so far as, the total amount of those payments does not exceed the total amount of the reductions within section 197(4).

2

Payments to which this subsection applies—

a

are not to be taken into account in calculating for the purposes of corporation tax the profits or losses of the guarantor company or companies or the issuing company, and

b

are not for any purpose of the Corporation Tax Acts to be regarded as distributions.

3

In this section, the following expressions have the meaning given by section 197—

  • “the balancing payments”,

  • “the guarantor company”, and

  • “the issuing company”.