Corporation Tax Act 2009 section 107

Accounting periods beginning before 1 January 2003

Section 107 prevents a double tax benefit where expenses relating to the provision of shares have already been deducted in calculating chargeable profits for an accounting period beginning before 1 January 2003.

• Part 12 relief for shares acquired is restricted where a deduction for related expenses has already been claimed
• The restriction applies to deductions made in accounting periods beginning before 1 January 2003
• It covers expenses of the employing company or any other company that are referable, directly or indirectly, to the provision of the shares
• The purpose is to prevent a double deduction — once under the old rules and again under Part 12