Corporation Tax Act 2009 section 1277

Withdrawal of relief: income that arose in an accounting period ending before 1 October 1993

Section 1277, read with Schedule 2 paragraph 135, provides a transitional rule that protects certain older unremittable income from being charged to tax when relief is withdrawn after the income source has ceased.

• Section 1277 normally charges income to corporation tax when unremittable income relief is withdrawn after the original source of that income has ceased to exist.
• However, this charge does not apply where the income in question originally arose in an accounting period that ended before 1 October 1993.
• This is a transitional provision preserving the previous tax treatment for income earned before that date.
• If the income arose in an accounting period ending on or after 1 October 1993, the normal withdrawal of relief rules under section 1277 apply in full.