Corporation Tax Act 2009 section 93

Capital receipts

Section 93 establishes the general rule that capital receipts must be excluded from the calculation of trading profits, while recognising specific statutory exceptions.

• Receipts of a capital nature must not be included when calculating the profits of a trade for corporation tax purposes.
• This reflects a long-established principle that capital receipts are kept separate from income when computing taxable trading profits.
• The general exclusion is overridden where a specific provision of the Corporation Tax Acts requires a capital sum to be brought into account as a trading receipt.
• Examples of such statutory exceptions include sums recovered under insurance policies, and rules governing loan relationships, derivative contracts, and intangible fixed assets.