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Corporation Tax Act 2009

▸ Part 1 – Introduction
  • Section A1 – Overview of the Corporation Tax Acts
  • Section 1 – Overview of Act
▸ Part 2 – Charge to corporation tax: basic provisions
  • ▸ Chapter 1 – The charge to corporation tax
    • Charge to tax on profits
    • General scheme of corporation tax
  • ▸ Chapter 2 – Accounting periods
    • Section 9 – Beginning of accounting period
    • Section 10 – End of accounting period
    • Section 11 – Companies with more than one accounting date
    • Section 12 – Companies being wound up
  • ▸ Chapter 3 – Company residence
    • Section 13 – Overview of Chapter
    • Section 14 – Companies incorporated in the United Kingdom
    • Section 15 – Continuation of residence established under common law
    • Section 16 – SEs which transfer registered office to the United Kingdom
    • Section 17 – SCEs which transfer registered office to the United Kingdom
    • Section 18 – Companies treated as non-UK resident under double taxation arrangements
  • ▸ Chapter 3A – UK Resident companies: profits of foreign permanent establishments
    • Exemption
    • Anti-diversion rule
    • Companies with total opening negative amount
    • Special cases
    • Interpretation
  • ▸ Chapter 4 – Non-UK resident companies: chargeable profits
    • Chargeable profits
    • The separate enterprise principle
    • The separate enterprise principle: application to non-UK resident banks
    • Rules about deductions
  • ▸ Chapter 5 – Supplementary
    • Section 33 – Trade includes office
▸ Part 3 – Trading Income
  • ▸ Chapter 2 – Income taxed as trade profits
    • Charge to tax on trade profits
    • Trades and trade profits
    • Starting and ceasing to trade
    • Trading income and property income
  • ▸ Chapter 9 – Trade profits: other specific trades
    • Dealers in securities etc.
    • Insurers
    • Building societies
    • Registered societies
    • Credit unions
    • Banking companies
    • Dealers in land etc.
    • Mineral exploration and access
    • Companies liable to pool betting duty
    • Intermediaries treated as making employment payments
    • Managed service companies
    • Worker's services provided through intermediary to public authority or medium or large client
    • Waste disposal
    • Cemeteries and crematoria: interests in land
    • Crematoria: niches, memorials and inscriptions
    • Sound recordings
    • Reserves of marketing authorities etc.
  • ▸ Chapter 8A – Compensation for compulsory slaughter of animals
    • Section 127A – Application of Chapter 8A
    • Section 127B – Right to make claim
    • Section 127C – Book value
    • Section 127D – Effect of claim for spreading of profits
    • Section 127E – Adjustment: cessation of trading
    • Section 127F – Time limits etc. for spreading claim
    • Section 127G – Interpretation
  • ▸ Chapter 8 – Trade profits: herd basis rules
    • Introduction
    • The herd basis rules
    • Elections
    • Preventing abuse of the herd basis rules
    • Supplementary
  • ▸ Chapter 7 – Trade profits: gifts to charities etc.
    • Relief for certain gifts
    • Benefits associated with gifts
  • ▸ Chapter 6A – Trade profits: R&D expenditure credits
    • Claims for credits
    • SMEs: qualifying expenditure on sub-contracted R&D
    • SMEs: subsidised qualifying expenditure
    • SMEs: capped R&D expenditure
    • Large companies: qualifying R&D expenditure
    • Amount of credit
    • Payment of credit
    • Insurance companies
    • Group companies
    • Ineligible companies
    • Anti-avoidance
    • Interpretation
  • ▸ Chapter 6 – Trade profits: receipts
    • Capital receipts
    • Debts released
    • Amounts received following earlier cessation
    • Reverse premiums
    • Other receipts
  • ▸ Chapter 5 – Trade Profits: Rules Allowing Deductions
    • Pre-trading expenses
    • Tenants under taxed leases
    • Payments for restrictive undertakings
    • Seconded employees
    • Contributions to agents' expenses
    • Counselling and retraining expenses
    • Redundancy payments etc.
    • Contributions to local enterprise organisations or urban regeneration companies
    • Contributions to flood and coastal erosion risk management projects
    • Scientific research
    • Expenses connected with patents, designs and trade marks
    • Export Credits Guarantee Department
    • Levies under FISMA 2000
    • Limited liability partnerships: salaried members
  • ▸ Chapter 4 – Trade profits: rules restricting deductions
    • Section 53 – Capital expenditure
    • Section 54 – Expenses not wholly and exclusively for trade and unconnected losses
    • Section 55 – Bad debts
    • Section 56 – Car hire
    • Section 57 – Car hire: supplementary
    • Section 58 – Hiring cars (but not motor cycles) with low CO 2 emissions before 1 April 2013
    • Section 58A – Short-term hiring in and long-term hiring out
    • Section 58B – Connected persons: application of section 56
    • Section 59 – Patent royalties
    • Section 60 – Expenditure on integral features
    • Section 60A – Rental rebates
  • ▸ Chapter 3 – Trade profits: basic rules
    • Section 46 – Generally accepted accounting practice
    • Section 47 – Losses calculated on same basis as profits
    • Section 48 – Receipts and expenses
    • Section 49 – Items treated as receipts and expenses
    • Section 50 – Animals kept for trade purposes
    • Section 51 – Relationship between rules prohibiting and allowing deductions
    • Section 52 – Apportionment etc. of profits and losses to accounting period
    • Section 49A – Money’s worth
  • ▸ Chapter 1 – Introduction
    • Section 34 – Overview of Part
  • ▸ Chapter 10 – Trade Profits: Changes in Trading Stock
    • Introduction
    • Transfers of trading stock between trade and trader
    • Other disposals and acquisitions not made in the course of trade
    • Relationship with transfer pricing rules
  • ▸ Chapter 11 – Trade Profits: Valuation of Stock on Cessation of Trade
    • Section 162 – Valuation of trading stock on cessation
    • Section 163 – Meaning of "trading stock"
    • Section 164 – Basis of valuation of trading stock
    • Section 165 – Sale basis of valuation: sale to unconnected person
    • Section 166 – Sale basis of valuation: sale to connected person
    • Section 167 – Sale basis of valuation: election by connected persons
    • Section 168 – Connected persons
    • Section 169 – Cost to buyer of stock valued on sale basis of valuation
    • Section 170 – Meaning of "sale" and related expressions
    • Section 171 – Determination of questions
  • ▸ Chapter 12 – Deductions from profits: unremittable amounts
    • Section 172 – Application of Chapter
    • Section 173 – Relief for unremittable amounts
    • Section 174 – Restrictions on relief
    • Section 175 – Withdrawal of relief
  • ▸ Chapter 13 – Disposal and acquisition of know-how
    • Section 176 – Meaning of "know-how" etc
    • Section 177 – Disposal of know-how if trade continues to be carried on
    • Section 178 – Disposal of know-how as part of disposal of all or part of a trade
    • Section 179 – Seller controlled by buyer etc.
  • ▸ Chapter 14 – Adjustment on change of basis
    • Adjustment on change of basis
    • Expenses previously brought into account
    • Realising or writing off assets
    • Mark to market
  • ▸ Chapter 15 – Post-cessation receipts
    • Charge to tax on post-cessation receipts
    • Meaning of “post-cessation receipts”
    • Sums treated as post-cessation receipts
    • Sums that are not post-cessation receipts
    • Deductions
    • Election to carry back
  • ▸ Chapter 16 – Priority rules
    • Section 201 – Provisions which must be given priority over this Part
▸ Part 4 – Property income
  • ▸ Chapter 1 – Introduction
    • Section 202 – Overview of Part
  • ▸ Chapter 2 – Property businesses
    • Introduction
    • Basic meaning of UK and overseas property business
    • Generating income from land
  • ▸ Chapter 3 – Profits of property businesses: basic rules
    • Charge to tax on profits of a property business
    • Calculation of profits
  • ▸ Chapter 4 – Profits of property businesses: lease premiums etc.
    • Introduction
    • Amounts treated as receipts: leases
    • Other amounts treated as receipts
    • Additional calculation rule for reducing certain receipts
    • Deductions in relation to certain receipts
    • Limit on effect of additional calculation rule and deductions
    • Certain administrative provisions
    • Determinations affecting liability of more than one person
    • Effective duration of lease
    • Other interpretative provisions
  • ▸ Chapter 5 – Profits of property businesses: other rules about receipts and deductions
    • Furnished accommodation: receipts and deductions
    • Treatment of receipts on acquisition of business
    • Reverse premiums as receipts
    • Deduction for replacement of domestic items
    • Deductions for expenditure on energy-saving items
    • Deductions for expenditure on sea walls
    • Mineral royalties
    • Apportionments on sale of land
    • Mutual business
    • Adjustment on change of basis
    • Integral features
  • ▸ Chapter 6 – Commercial letting of furnished holiday accommodation
    • Introduction
    • Definition
    • Separate profit calculations
  • ▸ Chapter 7 – Rent receivable in connection with a UK section 39(4) concern
    • Charge to tax on rent receivable in connection with a UK section 39(4) concern
    • Management expenses of owner of mineral rights
    • Mineral royalties
  • ▸ Chapter 8 – Rent receivable for UK electric-line wayleaves
    • Charge to tax on rent receivable for UK electric-line wayleaves
  • ▸ Chapter 9 – Post-cessation receipts
    • Charge to tax on post-cessation receipts
    • Meaning of “post-cessation receipts”
    • Deductions
    • Election to carry back
  • ▸ Chapter 10 – Supplementary
    • Priority rules
    • Other supplementary provisions
▸ Part 5 – Loan Relationships
  • ▸ Chapter 2 – Basic definitions
    • Section 302 – "Loan relationship", "creditor relationship", "debtor relationship"
    • Section 303 – "Money debt"
    • Section 304 – "Related transaction"
    • Section 305 – Payments, interest, rights and liabilities under a loan relationship
  • ▸ Chapter 3 – The credits and debits to be brought into account: general
    • Introduction
    • Matters in respect of which amounts are to be brought into account
    • General principles about the bringing into account of credits and debits
    • Amounts recognised in determining a company's profit or loss
    • Accounting bases
    • Adjustments on change of accounting basis
    • Rules differing from generally accepted accounting practice
    • Exchange gains and losses
    • Pre-loan relationship, abortive and pre-trading expenses
    • Pre-commencement debits of property businesses etc. of non-UK resident companies
    • Company is not, or has ceased to be, party to loan relationship
    • Company ceasing to be party to loan relationship
    • Company moving abroad
  • ▸ Chapter 4 – Continuity of treatment on transfers within groups or on reorganisations
    • Application of this Chapter
    • Continuity of treatment: transfer of loan at notional carrying value
    • Transferee leaving group after replacing transferor as party to loan relationship
  • ▸ Chapter 5 – Connected companies relationships: introduction and general
    • Section 348 – Introduction: meaning of "connected companies relationship"
    • Section 349 – Application of amortised cost basis to connected companies relationships
    • Section 350 – Companies beginning to be connected
    • Section 351 – Companies ceasing to be connected
    • Section 352 – Disregard of related transactions
    • Section 352B – Eliminating tax mismatch for loan relationships with qualifying link
    • Section 352A – Exclusion of credits on reversal of disregarded loss
  • ▸ Chapter 6 – Connected companies relationships: impairment losses and releases of debts
    • Introduction
    • Exclusion of debits for impaired or released connected companies debts
    • Exclusion of credits for connected companies debts on release or reversal of impairments
    • Deemed debt releases on impaired debts becoming held by connected company
  • ▸ Chapter 7 – Group relief claims involving impaired or released consortium debts
    • Section 364 – Introduction to Chapter
    • Section 365 – Reduction of impairment loss debits where group relief claimed
    • Section 366 – Effect where credit for release brought into account on amortised cost basis
    • Section 367 – Reduction of credits exceeding impairment losses
    • Section 368 – Reduction of claims where there are earlier net consortium debits
    • Section 369 – Carry forward of claims where there are no net consortium debits
    • Section 370 – Group accounting periods
    • Section 371 – Interpretation
  • ▸ Chapter 8 – Connected parties relationships: late interest
    • Section 372 – Introduction to Chapter
    • Section 373 – Late interest treated as not accruing until paid in some cases
    • Section 374 – Connection between debtor and person standing in position of creditor
    • Section 375 – Loans to close companies by participators etc
    • Section 376 – Interpretation of section 375
    • Section 377 – Party to loan relationship having major interest in other party
    • Section 378 – Loans by trustees of occupational pension schemes
    • Section 379 – Persons indirectly standing in the position of creditor
  • ▸ Chapter 9 – Partnerships involving companies
    • Section 380 – Partnerships involving companies
    • Section 381 – Determinations of credits and debits by company partners: general
    • Section 382 – Company partners using fair value accounting
    • Section 383 – Lending between partners and the partnership
    • Section 384 – Treatment of exchange gains and losses
    • Section 385 – Company partners’ shares where firm owns deeply discounted securities
  • ▸ Chapter 1 – Introduction
    • Introduction
    • How profits and deficits from loan relationships are dealt with
  • ▸ Chapter 16A – Non-trading deficits: post 1 April 2017 deficits
    • Section 463A – Introduction to Chapter
    • Section 463B – Claim to set off deficit against profits of deficit period or earlier periods
    • Section 463C – Time limits for claims under section 463B(1)
    • Section 463D – Claim to set off deficit against profits for the deficit period
    • Section 463E – Claim to carry back deficit to earlier periods
    • Section 463F – Profits available for relief under section 463E
    • Section 463G – Carry forward of unrelieved deficit against total profits
    • Section 463H – Carry forward of unrelieved deficit against non-trading profits
    • Section 463I – Re-application of section 463G if any deficit remains after previous application
  • ▸ Chapter 18 – General and supplementary provisions
    • Changes in accounting standards
    • Tax-adjusted carrying value
    • Connections between persons
    • Meaning of “hedging relationship”
    • Meaning of “matched”
    • Meaning of “hybrid capital instrument”
    • Other general definitions
  • ▸ Chapter 17 – Priority rules
    • Section 464 – Priority of this Part for corporation tax purposes
    • Section 465 – Exclusion of distributions except in tax avoidance cases
  • ▸ Chapter 16 – Non-trading deficits
    • Section 456 – Introduction to Chapter
    • Section 457 – Basic rule for deficits: carry forward to accounting periods after deficit period
    • Section 458 – Claim to carry forward deficit to later accounting periods
    • Section 459 – Claim to set off deficit against profits of deficit period or earlier periods
    • Section 460 – Time limits and procedure for claims under section 459(1)
    • Section 461 – Claim to set off deficit against other profits for the deficit period
    • Section 462 – Claim to carry back deficit to earlier accounting periods
    • Section 463 – Profits available for relief under section 462
  • ▸ Chapter 15 – Tax avoidance
    • Introduction
    • Unallowable purposes and tax relief schemes
    • Transactions not at arm's length: general
    • Non-market loans
    • Transactions not at arm's length: exchange gains and losses
    • Transactions not at arm's length: exchange gains and losses
    • Tax advantages from resetting interest rates (“reset bonds”)
    • Disposals for consideration not fully recognised by accounting practice
    • Derecognition
    • Counteracting avoidance arrangements
  • ▸ Chapter 14 – European cross-border mergers
    • Introduction
    • Transfers of loan relationships at notional carrying value
    • Exception for tax avoidance cases
    • Transparent entities
    • Interpretation
  • ▸ Chapter 13 – European cross-border transfers of business
    • Introduction
    • Transfers of loan relationships at notional carrying value
    • Exception for tax avoidance cases
    • Transparent entities
    • Interpretation
  • ▸ Chapter 12 – Special rules for particular kinds of securities
    • Introduction
    • Index-linked gilt-edged securities
    • Other gilt-edged securities
    • Deeply discounted securities: connected companies and close companies
    • Funding bonds
    • Derivatives
    • Options etc.
    • Hybrid capital instruments
  • ▸ Chapter 11 – Other special kinds of company
    • Investment trusts' and venture capital trusts' creditor relationships
    • Credit unions
  • ▸ Chapter 10 – Insurance companies
    • Introduction
    • Treatment of deficit on basic life assurance and general annuity business
    • Exclusion of loan relationships of members of Lloyd's
▸ Part 6 – Relationships treated as loan relationships etc
  • ▸ Chapter 1 – Introduction
    • Section 477 – Overview of Part
  • ▸ Chapter 2 – Relevant non-lending relationships
    • Introduction: meaning of “relevant non-lending relationship” etc.
    • Application of Part 5 to relevant non-lending relationships
    • Meaning of “money debt” and “interest” in this Chapter
    • Exclusions
  • ▸ Chapter 2A – Disguised interest
    • Section 486A – Overview
    • Section 486B – Disguised interest to be regarded as profit from loan relationship
    • Section 486C – Exclusion where return otherwise taxable
    • Section 486D – Exclusion where arrangement has no tax avoidance purpose
    • Section 486E – Excluded shares
  • ▸ Chapter 2B – Transferred income streams
    • Section 486F – Introduction to Chapter
    • Section 486G – Consideration to be treated as loan relationship
  • ▸ Chapter 3 – OEICs, unit trusts and offshore funds
    • Introduction
    • Holdings in OEICs, unit trusts and offshore funds treated as creditor relationship rights
    • The qualifying investments test
    • Power to change investments that are qualifying investments
  • ▸ Chapter 4 – Building Societies
    • Section 498 – Building society dividends and interest
  • ▸ Chapter 5 – Industrial and provident societies
    • Section 499 – Industrial and provident society payments treated as interest under loan relationship
    • Section 500 – Exclusion of interest where failure to make return
  • ▸ Chapter 6 – Alternative finance arrangements
    • Introduction
    • Arrangements that are alternative finance arrangements
    • Treatment as loan relationships
    • Meaning of “alternative finance return”
    • Treatment for other tax purposes
    • Power to extend this Chapter to other arrangements
  • ▸ Chapter 7 – Shares with guaranteed returns etc
    • Application of Part 5 to certain shares as rights under creditor relationship
    • Shares subject to outstanding third party obligations
    • Non-qualifying shares
    • Consequences of section 523 applying or ceasing to apply
  • ▸ Chapter 8 – Returns from partnerships
    • Section 536 – Introduction to Chapter
    • Section 537 – Payments in return for capital contribution to partnership
    • Section 538 – Change of partnership shares
  • ▸ Chapter 9 – Manufactured interest etc
    • Section 539 – Introduction to Chapter
    • Section 540 – Manufactured interest treated as interest under loan relationship
    • Section 541 – Debits for deemed interest under stock lending arrangements disallowed
  • ▸ Chapter 10 – Repos
    • Introduction
    • Creditor repos and creditor quasi-repos
    • Debtor repos and debtor quasi-repos
    • General provisions
    • Interpretation (556-559)
  • ▸ Chapter 6A – Shares accounted for as liabilities
    • Section 521F – Shares becoming or ceasing to be shares to which section 521B applies
    • Section 521E – Unallowable purpose
    • Section 521D – Excepted shares
    • Section 521C – Shares accounted for as liabilities
    • Section 521B – Application of Part 5 to certain shares as rights under creditor relationship
    • Section 521A – Introduction to Chapter
  • ▸ Chapter 11 – Investment life insurance contracts
    • Introduction
    • Investment life assurance contracts treated as creditor relationships
    • Old accounting period contracts
▸ Part 7 – Derivative contracts
  • ▸ Chapter 1 – Introduction
    • Introduction
    • How profits and losses from derivative contracts are dealt with
  • ▸ Chapter 2 – Contracts to which this Part applies
    • Introduction
    • Meaning of “derivative contract” and other basic definitions
    • Cases where companies treated as parties to relevant contracts
    • Other contracts etc. treated as derivative contracts
    • Exclusions from derivative contracts
  • ▸ Chapter 3 – Credits and debits to be brought into account: general
    • Introduction
    • Matters in respect of which amounts are to be brought into account
    • General principles
    • Amounts recognised in determining a company's profit or loss
    • Application of fair value accounting
    • Rules differing from generally accepted accounting practice
    • Exchange gains and losses
    • Miscellaneous
  • ▸ Chapter 4 – Further provision about credits and debits to be brought into account
    • Introduction
    • Adjustments on change of accounting basis
    • Certain embedded derivatives
    • Partnerships involving companies
    • Miscellaneous
  • ▸ Chapter 5 – Continuity of treatment on transfers within groups
    • Introductory
    • Group member replacing another as party to derivative contract
    • Exceptions to section 625
    • Transferee leaving group after replacing transferor as party to derivative contract
  • ▸ Chapter 6 – Special kinds of company
    • Mutual trading companies
    • Insurance companies (634-636)
    • Investment and venture capital trusts (637-638)
  • ▸ Chapter 7 – Chargeable gains arising in relation to derivative contracts
    • Introduction
    • Some credits and debits not to be brought into account under Part 5
    • Some derivative contracts to be taxed on a chargeable gains basis
    • Derivative contracts to which sections 640 and 641 apply
    • Some credits and debits not to be brought into account under Part 3 or 5
    • Issuers of securities with embedded derivatives: deemed options
    • Issuers of securities with embedded derivatives: deemed contracts for differences
    • Interpretation
  • ▸ Chapter 8 – Further provision about chargeable gains and derivative contracts
    • Company ceasing to be party to certain contracts
    • Contracts ceasing to be derivative contracts
    • Carry back of net losses on certain derivative contracts
    • Issuers of securities with embedded derivatives: equity instruments
    • Treatment of shares acquired in certain circumstances
    • Treatment of net gains and losses on exercise of option
    • Treatment of net gains and losses on disposal of certain embedded derivatives
  • ▸ Chapter 9 – European cross-border transfers of business
    • Introduction
    • Transfers of derivative contracts at notional carrying value
    • Exception for tax avoidance cases and clearances
    • Transparent entities
    • Interpretation
  • ▸ Chapter 10 – European cross-border mergers
    • Introduction
    • Transfers of derivative contracts at notional carrying value
    • Exception for tax avoidance cases and clearances
    • Transparent entities
    • Interpretation
  • ▸ Chapter 11 – Tax avoidance
    • Introduction
    • Unallowable purposes
    • Transactions not at arm's length
    • Transactions with non-UK residents
    • Disposals for consideration not fully recognised by accounting practice
    • Derecognition
    • Counteracting avoidance arrangements
  • ▸ Chapter 12 – Priority rules
    • Section 699 – Priority of this Part for corporation tax purposes
    • Section 700 – Relationship of this Part to Part 5: loan relationships
  • ▸ Chapter 13 – General and supplementary provisions
    • Power to amend certain provisions
    • Changes to accounting standards
    • Other general definitions
▸ Part 8 – Intangible fixed assets
  • ▸ Chapter 2 – Credits in respect of intangible fixed assets
    • Section 720 – Introduction
    • Section 721 – Receipts recognised as they accrue
    • Section 722 – Receipts in respect of royalties so far as not dealt with under section 721
    • Section 723 – Revaluation
    • Section 724 – Negative goodwill
    • Section 725 – Reversal of previous accounting loss
  • ▸ Chapter 3 – Realisation of intangible fixed assets
    • Section 726 – Introduction
    • Section 727 – References to expenditure on an asset
    • Section 728 – Expenditure written off as it is incurred
    • Section 729 – Writing down on accounting basis
    • Section 730 – Writing down at fixed rate: election for fixed-rate basis
    • Section 731 – Writing down at fixed rate: calculation
    • Section 732 – Reversal of previous accounting gain
  • ▸ Chapter 4 – Realisation of intangible fixed assets
    • Section 733 – Overview of Chapter
    • Section 734 – Meaning of “realisation”
    • Section 735 – Asset written down for tax purposes
    • Section 736 – Asset shown in balance sheet and not written down for tax purposes
    • Section 737 – Apportionment in case of part realisation
    • Section 738 – Asset not shown in balance sheet
    • Section 739 – Meaning of “proceeds of realisation”
    • Section 740 – Abortive expenditure on realisation
    • Section 741 – Meaning of “chargeable intangible asset” and “chargeable realisation gain”
  • ▸ Chapter 5 – Calculation of tax written-down value
    • Section 742 – Asset written down on accounting basis
    • Section 743 – Asset written down at fixed rate
    • Section 744 – Effect of part realisation of asset
  • ▸ Chapter 6 – How credits and debits are given effect
    • Introductory
    • Trading etc. credits and debits
    • Non-trading credits and debits (751-753)
  • ▸ Chapter 7 – Roll-over relief in case of realisation and reinvestment
    • When the relief is given
    • How the relief is given
  • ▸ Chapter 8 – Groups of companies: introduction
    • Introductory
    • Rules
  • ▸ Chapter 9 – Application of this Part to groups of companies
    • Introductory
    • Transfers within a group treated as tax-neutral
    • Roll-over relief under Chapter 7 (realisation and reinvestment)
    • Company ceasing to be member of group
    • Reallocation of degrouping charge within group and recovery
    • Disregard of payments between group members for reliefs
  • ▸ Chapter 1 – Introduction
    • Introductory
    • Basic definitions
    • Goodwill
    • Accounting rules and definitions
  • ▸ Chapter 15 – Adjustments on change of accounting policy
    • Introductory
    • Change of policy involving change of value
    • Change of policy involving disaggregation
    • Supplementary
  • ▸ Chapter 14 – Miscellaneous provisions
    • Grants and other contributions to expenditure
    • Finance leasing
    • Values to be used in special cases
    • Fungible assets
    • Assets ceasing to be or becoming chargeable intangible assets
    • Matters to be ignored
    • Delayed payments and bad debts (866-870)
    • Roll-over relief under TCGA 1992
  • ▸ Chapter 13 – Transactions between related parties
    • Introductory
    • Transfers treated as being at market value
    • Grants treated as being at market value
    • Other rules
  • ▸ Chapter 12 – Related parties
    • Introductory
    • Meaning of “related party”, “control” and “major interest”
    • Rights and powers to be taken into account
    • Meaning of “participator” and “associate”
    • Connected persons
  • ▸ Chapter 11 – Transfer of business or trade
    • Introduction
    • Tax-neutral transfers
    • Transfer of assets to non-UK resident company
    • The genuine commercial transaction requirement and clearance
  • ▸ Chapter 10 – Excluded assets
    • Introductory
    • Assets wholly excluded from this Part
    • Assets excluded from this Part except as respects royalties
    • Assets excluded from this Part to the extent specified
  • ▸ Chapter 16B – Fungible assets
    • Section 900J – Fungible assets: general
    • Section 900K – Fungible assets: pre-FA 2002 assets and restricted assets
    • Section 900L – Realisation of fungible assets: pre-FA 2002 assets and restricted assets
    • Section 900M – Acquisition of fungible assets: pre-FA 2002 assets and restricted assets
    • Section 900N – Debits in respect of a single asset comprising restricted assets
    • Section 900O – Interpretation
  • ▸ Chapter 16A – Debits in respect of assets that were pre-FA 2002 assets etc.
    • Introduction
    • When an intangible fixed asset is a restricted asset
    • The special rules
    • Supplementary provisions (900G-900I)
  • ▸ Chapter 15A – Debits in respect of goodwill and certain other assets
    • Introduction
    • Requirement to write down at a fixed rate
    • Restrictions on debits: pre-FA 2019 relevant assets
    • Restrictions on debits: no business or no qualifying IP assets acquired
    • Restrictions on debits: acquisition from individual or firm
    • Partial restrictions on debits
    • Supplementary
  • ▸ Chapter 18 – Priority rules
    • Section 906 – Priority of this Part for corporation tax purposes
  • ▸ Chapter 17 – Insurance companies
    • Effect of application of the I minus E basis: non-trading amounts
    • Miscellaneous
  • ▸ Chapter 16 – Pre-FA 2002 assets etc.
    • Introduction
    • General rule
    • When assets are treated as created or acquired
    • When expenditure treated as incurred
    • Fungible assets
    • Assets treated as pre-FA 2002 assets
    • Application of Part to royalties and telecommunication rights
    • Roll-over relief for disposals of pre-FA 2002 assets
▸ Part 9 – Intellectual property: know-how and patents
  • ▸ Chapter 1 – Introduction
    • Section 907 – Overview of Part
  • ▸ Chapter 2 – Disposals of know-how
    • Section 908 – Charge to tax on profits from disposals of know-how
    • Section 909 – Exceptions to charge under section 908
    • Section 910 – Profits charged under section 908
  • ▸ Chapter 3 – Sales of patent rights
    • Introductory
    • Charge to tax
    • Spreading of charge to tax
    • Miscellaneous
  • ▸ Chapter 4 – Relief from corporation tax on patent income
    • Section 924 – Relief for expenses: patent income
    • Section 925 – How relief is given under section 924
  • ▸ Chapter 5 – Supplementary
    • Section 926 – Contributions to expenditure
    • Section 927 – Contributions not made by public bodies nor eligible for tax relief
    • Section 928 – Exchanges
    • Section 929 – Apportionment where property sold together
    • Section 930 – Questions about apportionments affecting two or more persons
    • Section 931 – Meaning of “capital sums” etc.
▸ Part 9A – Company distributions
  • ▸ Chapter 1 – The charge to Tax
    • Section 931A – Charge to tax on distributions received
  • ▸ Chapter 2 – Exemption of distributions received by small companies
    • Section 931B – Exemption from charge to tax
    • Section 931C – Meaning of “qualifying territory”