Corporation Tax Act 2009 section 982

Provisions which must be given priority over this Part

Section 982 establishes which part of the Corporation Tax Act takes priority when income could potentially be taxed under more than one set of rules — specifically where income falls within both the miscellaneous income provisions and the rules for trading income or property income.

• Where income falls within both the miscellaneous income rules (Chapter 6 of Part 10) and the trading income rules (Part 3), it must be taxed under the trading income rules in Part 3
• Where income falls within both the miscellaneous income rules (Chapter 6 of Part 10) and the UK property business rules (Part 4), it must be taxed under the property income rules in Part 4
• Trading income and property income always take priority over a miscellaneous income charge, preventing the same income from being taxed twice under different provisions
• This priority rule formalises what was historically known as the "Crown Option" regarding overlapping income categories