Corporation Tax Act 2009 section 7

Profits accruing under trusts

Section 7 deals with how profits held for a company's benefit under a trust are treated for corporation tax purposes.

• Where profits accrue for a company's benefit under a trust, they are treated as if they accrued directly to the company.
• This means the profits are subject to corporation tax in exactly the same way as if the company had earned them directly.
• The trust structure does not provide any shield or different treatment for corporation tax purposes.
• This section applies only to trusts — separate rules elsewhere in the Act (particularly Part 17) deal with profits arising through partnerships.