Corporation Tax Act 2009 section 866

Delayed payment of employees' remuneration

Section 866 restricts the timing of tax deductions for employees' remuneration that falls within the intangible fixed assets rules, where that remuneration is not paid promptly after the accounting period in which it is recognised.

• Where employees' remuneration is recognised as a debit for accounting purposes and would normally be deductible under the intangible fixed assets rules, a timing restriction applies.
• The deduction is only allowed if the remuneration is actually paid within 9 months of the end of the period of account in which the debit is recognised.
• If the remuneration is paid after the 9-month deadline, the deduction is deferred and is instead allowed in the period of account in which payment is actually made.
• Further supplementary provisions relating to this restriction are set out in section 867.