Corporation Tax Act 2009 section 1232

Chapter applies to amounts not otherwise relieved

Section 1232 establishes a priority rule preventing amounts from being treated as management expenses under Chapter 3 if they already qualify for relief elsewhere.

• Chapter 3 only treats amounts as expenses of management where they would not already qualify under the general rule in Chapter 2
• Amounts that are otherwise deductible from total profits, or in calculating any component of total profits, are excluded from Chapter 3
• This is a priority rule: Chapter 2's general management expenses rule in section 1219(1) always takes precedence over the provisions in Chapter 3
• The effect is to prevent a double deduction by ensuring Chapter 3 acts as a backstop for amounts not relieved through any other route