Corporation Tax Act 2009 section 235

Limit on reductions and deductions

Section 235 caps the total relief available under this chapter in relation to a taxed lease premium receipt, ensuring that combined reductions and deductions cannot exceed the original taxed amount less any relief already given elsewhere.

• Total relief (reductions under the additional calculation rule and property business expense deductions) linked to a taxed receipt is subject to an overall cap
• The cap equals the unreduced taxed receipt minus any income tax reductions or deductions already claimed against the same receipt
• Relief already given under the corresponding income tax provisions (ITTOIA 2005) and any trading expense deductions referencing the same receipt must be taken into account
• The restriction prevents the aggregate of all corporation tax and income tax reliefs from exceeding the original premium amount brought into charge