Corporation Tax Act 2009 section 1179CD

Treatment of notional tax deduction

Section 1179CD explains what happens to the notional tax amount that is deducted from a qualifying company's expenditure credit, including how it can be surrendered to group companies or carried forward to offset future corporation tax liabilities.

  • The notional tax deducted from the expenditure credit can be surrendered to other group members in the same accounting period
  • Any amount not surrendered is carried forward to the company's next accounting period
  • The carried-forward amount is first used to discharge the company's own corporation tax liability for that next period
  • Any remaining balance after offsetting corporation tax can again be surrendered to group members or, failing that, carried forward once more โ€” and the process repeats

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