Corporation Tax Act 2009 Explanatory Notes

Section 235: Limit on reductions and deductions

866.This section places a limit on the relief that can be given under this Chapter in relation to a taxed receipt. It is based on section 37(9) of ICTA. The corresponding provision for income tax is in section 295 of ITTOIA.

867.The section restricts total relief in respect of a taxed receipt by way of:

  • reductions under the additional calculation rule in section 228; and

  • deductions under section 232.

868.The total relief is restricted to the amount of the taxed receipt after the following (so far as given by reference to the taxed receipt):

  • any reductions or deductions under sections 288 or 292 of ITTOIA (which correspond to sections 228 and 232 respectively); and

  • any deductions under section 63 (trading expense), or under section 61 of ITTOIA (which corresponds to section 63).

See Change 49 in Annex 1.

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