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Corporation Tax Act 2010

▸ Part 1 – Introduction
  • Section 1 – Overview of Act
▸ Part 2 – Calculation of liability in respect of profits
  • ▸ Chapter 1 – Introduction
    • Section 2 – Overview of Part
  • ▸ Chapter 2 – Rates at which corporation tax on profits charged
    • Section 3 – Corporation tax rates
  • ▸ Chapter 3 – Calculation of amount to which rates applied
    • Section 4 – Amount of profits to which corporation tax rates applied
  • ▸ Chapter 4 – Currency
    • The currency to be used in tax calculations
    • Translating amounts into other currencies
    • Adjustment of sterling losses
    • Interpretation
▸ Part 3 – Companies with small profits
  • ▸ The small profits rate
    • Section 18 – Profits charged at the small profits rate
  • ▸ Marginal relief
    • Section 23 – The remaining amount
    • Section 22 – The ring fence amount
    • Section 21 – Company with ring fence profits and other profits
    • Section 20 – Company with only ring fence profits
    • Section 19 – Marginal relief
  • ▸ The lower limit and the upper limit
    • Section 26 – Section 25(3): treatment of certain non-trading companies
    • Section 30 – Association through a trustee
    • Section 29 – Association through a loan creditor
    • Section 28 – Associated companies: fixed-rate preference shares
    • Section 27 – Attribution to persons of rights and powers of their associates
    • Section 25 – Associated companies
    • Section 24 – The lower limit and the upper limit
  • ▸ Supplementary
    • Section 34 – Close investment-holding companies
    • Section 33 – Interpretation of section 32(2) and (3)
    • Section 32 – Meaning of “augmented profits”
    • Section 31 – Power to obtain information
▸ Part 4 – Loss relief
  • ▸ Chapter 1 – Introduction
    • Section 35 – Overview of Part
  • ▸ Chapter 2 – Trade losses
    • Introduction
    • Relief in loss-making period and carry back relief
    • Carry forward of trade loss relief
    • Restrictions on relief: farming or market gardening
    • Restrictions on relief: commodity futures
    • Other restrictions on relief
  • ▸ Chapter 3 – Limited partners and members of limited liability partnerships
    • Introduction
    • Limited partners
    • Members of LLPs
  • ▸ Chapter 4 – Property losses
    • UK property businesses
    • Overseas property businesses
    • Insurance companies
  • ▸ Chapter 5 – Losses on disposal of shares
    • Share loss relief against income
    • Shares: subscription and disposal
    • Qualifying trading companies: the requirements
    • Qualifying trading companies: supplementary
    • Interpretation
  • ▸ Chapter 6 – Losses from miscellaneous transactions
    • Section 91 – Relief for losses from miscellaneous transactions
  • ▸ Chapter 7 – Write-off of government investment
    • Section 92 – Loss relief to be reduced if government investment is written off
    • Section 93 – Groups of companies
    • Section 94 – Cases in which government investment is written off
    • Section 95 – Meaning of “carry-forward losses”
    • Section 96 – Interaction with other tax provisions
▸ Part 5 – Group relief
  • ▸ Chapter 1 – Introduction
    • Section 97 – Introduction to Part
  • ▸ Chapter 2 – Surrender of company’s losses etc for an accounting period
    • Introduction
    • Basic provisions about surrendering losses and other amounts
    • Restrictions on losses and other amounts that may be surrendered
  • ▸ Chapter 3 – Surrenders made by non-UK resident company resident or trading in the EEA
    • Introduction
    • Basic provisions about surrendering losses and other amounts
    • Conditions that must be met
    • Other rules, assumptions and exclusions
  • ▸ Chapter 4 – Claims for group relief
    • Introduction
    • Surrenderable amounts under Chapter 2
    • Surrenderable amounts under Chapter 3
    • Giving of group relief
    • General limitation on amount of group relief to be given
    • Limitations on group relief if claim based on consortium condition 1, 2 or 3
  • ▸ Chapter 5 – Subsidiaries, groups and consortiums
    • Introduction
    • Explanations of terms
    • Arrangements for transfers of companies
  • ▸ Chapter 6 – Equity holders and profits or assets available for distribution
    • Introduction
    • Equity holders
    • Company's entitlement to profits or assets available for distribution: basic provisions
    • Company's entitlement to profits or assets available for distribution: supplementary
  • ▸ Chapter 7 – Miscellaneous provisions and interpretation of Part
    • Miscellaneous
    • Interpretation
▸ Part 5A – Group relief for carried-forward losses
  • ▸ Chapter 1 – Introduction
    • Section 188AA – Introduction to Part
  • ▸ Chapter 2 – Surrender of company's carried-forward losses etc.
    • Section 188BA – Overview of Chapter
    • Section 188BB – Surrender of carried-forward losses and other amounts
    • Section 188BC – Restriction on surrendering pre-1 April 2017 losses etc.
    • Section 188BD – Restriction where investment business has become small or negligible
    • Section 188BE – Restriction where surrendering company could use losses etc. itself
    • Section 188BF – Restriction where surrendering company has no income-generating assets
    • Section 188BG – Restrictions for certain insurance companies
    • Section 188BH – Restriction on surrender of losses etc. made when UK resident
    • Section 188BI – Restriction on surrender of losses made when non-UK resident
    • Section 188BJ – Restriction on surrender losses etc. made when dual resident
  • ▸ Chapter 3 – Claims for group relief for carried-forward losses
    • Introduction
    • Claiming group relief for carried-forward losses
    • Giving group relief for carried-forward losses
  • ▸ Chapter 4 – Limitations on relief: claims under section 188CB
    • Introduction
    • General limitation on amount of relief
    • Further limitations on amount of relief if claim based on consortium conditions 1 or 2
  • ▸ Chapter 5 – Limitations on relief: claims under section 188CC
    • Introduction
    • General limitation on amount of relief
    • Further limitations on amount of relief that apply in particular cases
  • ▸ Chapter 6 – Miscellaneous provisions and interpretation of Part
    • Miscellaneous
    • Interpretation
▸ Part 6 – Charitable donations relief
  • ▸ Chapter 1 – Nature of relief
    • Section 189 – Relief for qualifying charitable donations
    • Section 190 – Qualifying charitable donations: meaning
  • ▸ Chapter 2 – Certain payments to charity
    • Qualifying payments
    • Payment attributed to earlier period
    • Interpretation
  • ▸ Chapter 2A – Payments to community amateur sports clubs: anti-abuse
    • Section 202B – Restriction on relief for payments to community amateur sports clubs
    • Section 202C – "Inflated member-related expenditure"
  • ▸ Chapter 3 – Certain disposals to charity
    • Amounts treated as qualifying charitable donations
    • Value of net benefit to charity
    • Special provisions about qualifying interests in land
    • Interpretation
▸ Part 6A – Relief for expenditure on grassroots sport
  • Section 217A – Relief for expenditure on grassroots sport
  • Section 217B – Meaning of qualifying expenditure on grassroots sport
  • Section 217C – Meaning of qualifying sport body
  • Section 217D – Relationship between this Part and Part 6
▸ Part 7 – Community investment tax relief
  • ▸ Chapter 1 – Introduction
    • CITR
    • Miscellaneous
  • ▸ Chapter 2 – Qualifying investments
    • Section 225 – Qualifying investments: introduction
    • Section 226 – Conditions to be met in relation to loans
    • Section 227 – Conditions to be met in relation to securities
    • Section 228 – Conditions to be met in relation to shares
    • Section 229 – Tax relief certificates
    • Section 230 – No pre-arranged protection against risks
  • ▸ Chapter 3 – General conditions
    • Section 231 – No control of CDFI by investor
    • Section 232 – Investor must have beneficial ownership
    • Section 233 – Investor must not be accredited
    • Section 234 – No acquisition of share in partnership
    • Section 235 – No tax avoidance purpose
  • ▸ Chapter 4 – Limitations on claims and attribution
    • Limitations on claims
    • Attribution
  • ▸ Chapter 5 – Withdrawal or reduction of CITR
    • Introduction
    • Disposals
    • Repayment of loans
    • Receipts of value
    • CITR not due
    • Manner of withdrawal or reduction
  • ▸ Chapter 6 – Supplementary and general
    • Alternative finance arrangements
    • Miscellaneous
    • Definitions
▸ Part 7ZA – Restrictions on obtaining certain deductions
  • ▸ Introduction
    • Section 269ZA – Overview of Part
  • ▸ Restrictions on obtaining certain deductions
    • Section 269ZBA – Restriction on deductions from chargeable gains
    • Section 269ZDA – References to a company’s “deductions allowance”
    • Section 269ZB – Restriction on deductions from trading profits
    • Section 269ZC – Restriction on deductions from non-trading profits
    • Section 269ZD – Restriction on deductions from total profits
    • Section 269ZE – Restriction on deductions from total profits: insurance companies
  • ▸ Relevant profits
    • Section 269ZFA – “Relevant profits”
    • Section 269ZF – “Relevant trading profits”, “total relevant non-trading profits” etc.
  • ▸ Modifications for certain insurance companies
    • Section 269ZFB – Modifications for certain insurance companies
    • Section 269ZFC – Restriction on deductions of non-BLAGAB allowable losses from BLAGAB chargeable gains
  • ▸ Exclusion for certain general insurance companies
    • Section 269ZJ – Exclusion of shock losses from restrictions
    • Section 269ZG – General insurance companies: excluded accounting periods
    • Section 269ZH – “Insolvency procedures”
    • Section 269ZI – “Qualifying latent claims”
    • Section 269ZK – Meaning of “shock loss”: requirement to make a claim
    • Section 269ZL – Further provision about claims under section 269ZK
    • Section 269ZM – Meaning of “solvency shock period”
    • Section 269ZN – Determination of shock loss threshold
    • Section 269ZO – Calculation of solvency loss
    • Section 269ZP – Interpretation of sections 269ZJ to 269ZO
    • Section 269ZQ – Power to amend
  • ▸ Deductions allowance
    • Section 269ZZB – Meaning of “group”
    • Section 269ZT – Group allowance allocation statement: submission
    • Section 269ZU – Group allowance allocation statement: submission of revised statement
    • Section 269ZV – Group allowance allocation statement: requirements and effects
    • Section 269ZW – Deductions allowance for company not in a group
    • Section 269ZX – Increase of deductions allowance in connection with onerous or impaired leases
    • Section 269ZY – Meaning of “relevant reversal credit”
    • Section 269ZZ – Company tax return to specify amount of deductions allowance
    • Section 269ZZA – Excessive specifications of deductions allowance
    • Section 269ZS – Group deductions allowance and the nominated company
    • Section 269ZWA – Increase of deductions allowance for insolvent companies
    • Section 269ZYA – Deductions allowance for company without a source of chargeable income
    • Section 269ZYB – Provisional application of section 269ZYA
    • Section 269ZR – Deductions allowance for company in a group
    • Section 269ZSA – Group allowance nomination: former groups
    • Section 269ZVA – Group allowance allocation statement: former groups
    • Section 269ZYZA – Other relevant credits
▸ Part 3A – Companies with small profits
  • ▸ The standard small profits rate for non-ring fence profits
    • Section 18A – Profits charged at the standard small profits rate
  • ▸ Marginal relief
    • Section 18B – Marginal relief for companies without ring fence profits
    • Section 18C – Marginal relief for companies with ring fence profits
  • ▸ The lower limit and the upper limit
    • Section 18D – The lower limit and the upper limit
    • Section 18E – Associated companies
    • Section 18F – Section 18E(3): treatment of certain non-trading companies
    • Section 18G – Attribution to persons of rights and powers of their partners
    • Section 18H – Associated companies: fixed-rate preference shares
    • Section 18I – Association through a loan creditor
    • Section 18J – Association through a trustee
  • ▸ Supplementary
    • Section 18K – Power to obtain information
    • Section 18L – Meaning of “augmented profits”
    • Section 18M – Interpretation of section 18L(3)
    • Section 18N – Close investment-holding companies
▸ Part 7A – Banking companies
  • ▸ Chapter 1 – Introduction
    • Section 269A – Overview of Part
  • ▸ Chapter 2 – Key definitions
    • “Banking company”
    • “Group”
    • Powers to amend
  • ▸ Chapter 3 – Restrictions on obtaining certain deductions
    • Introduction
    • Restrictions on obtaining certain deductions
    • Losses to which restrictions do not apply
    • Anti-avoidance
    • Supplementary
  • ▸ Chapter 4 – Surcharge on banking companies
    • Overview
    • The surcharge
    • Non-banking group relief
    • Non-banking or pre-2016 loss relief
    • The surcharge allowance
    • Application of Corporation Tax Acts: administration, double taxation etc.
    • Anti-avoidance
    • Interpretation
▸ Part 8 – Oil activities
  • ▸ Chapter 1 – Introduction
    • Section 270 – Overview of Part
  • ▸ Chapter 2 – Basic definitions
    • Section 271 – “Associated companies”
    • Section 272 – “Oil extraction activities”
    • Section 273 – “Oil rights”
    • Section 274 – “Oil-related activities”
    • Section 275 – “Ring fence income”
    • Section 276 – “Ring fence profits”
    • Section 277 – “Ring fence trade”
    • Section 278 – Other definitions
  • ▸ Chapter 3 – Deemed separate trade
    • Section 279 – Oil-related activities treated as separate trade
  • ▸ Chapter 3A – Rates at which corporation tax is charge on ring fence profits
    • The rates
    • Marginal relief
    • The lower limit and the upper limit
    • Supplementary
    • Related 51% group companies
    • Augmented profits
  • ▸ Chapter 4 – Calculation of profits
    • Oil valuation
    • Hire of relevant assets
    • Loan relationships
    • Sale and lease-back
    • Regional development grants
    • Tariff receipts etc.
    • Abandonment guarantees
    • Abandonment expenditure
    • Receipts arising from decommissioning
    • Deduction of PRT in calculating income for corporation tax purposes
    • Interest on repayment of PRT or APRT
    • Relief
  • ▸ Chapter 5 – Ring fence expenditure supplement
    • Introduction
    • Application and interpretation
    • Pre-commencement supplement
    • Post-commencement supplement
  • ▸ Chapter 5A – Extended ring fence expenditure supplement for onshore activities
    • Introduction
    • Application and interpretation
    • Pre-commencement additional supplement
    • Post-commencement additional supplement
  • ▸ Chapter 6 – Supplementary charge in respect of ring fence trades
    • Section 330 – Supplementary charge in respect of ring fence trades
    • Section 330ZA – Ordering of allowances
    • Section 330A – Decommissioning expenditure taken into account in calculating ring fence profits
    • Section 330B – Decommissioning expenditure taken into account for PRT purposes
    • Section 330C – Meaning of “decommissioning expenditure
    • Section 331 – Meaning of “financing costs” etc.
    • Section 332 – Assessment, recovery and postponement of supplementary charge
  • ▸ Chapter 7 – Reduction of supplementary charge for certain new oil fields
    • Reduction of adjusted ring fence profits
    • Pool of field allowances
    • Field allowance: when held and unactivated amount
    • No change in equity share: activation of allowance
    • Change in equity share: activation of allowance
    • Change in equity share: transfer of field allowance
    • Miscellaneous
    • Interpretation
  • ▸ Chapter 8 – Supplementary charge: onshore allowance
    • Introduction
    • Onshore allowance
    • Reduction of adjusted ring fence profits
    • Activated and unactivated allowance: basic calculation rules
    • Transfer of allowances between sites
    • Changes in equity share: activation of allowance
    • Transfers of allowance on disposal of equity share
    • Miscellaneous
    • Interpretation
  • ▸ Chapter 6A – Supplementary charge: investment allowance
    • Introduction
    • “Qualifying oil field” and “investment expenditure”
    • Investment allowance
    • Restrictions on relievable expenditure
    • Reduction of adjusted ring fence profits
    • Activated and unactivated allowance: basic calculation rules
    • Changes in equity share: reference periods
    • Changes in equity share: activation of allowance
    • Transfers of allowance on disposal of equity share
    • Miscellaneous
    • Interpretation
  • ▸ Chapter 9 – Supplementary charge: cluster area allowance
    • Introduction
    • Determination of cluster areas
    • Meaning of “investment expenditure”
    • Cluster area allowance
    • Reduction of adjusted ring fence profits
    • Activated and unactivated allowance: basic calculation rules
    • Changes in equity share: reference periods
    • Changes in equity share: activation of allowance
    • Transfers of allowance on disposal of equity share
    • Use of allowance attributable to unlicensed area
    • Miscellaneous
    • Interpretation
▸ Part 8ZA – Oil Contractors
  • ▸ Chapter 1 – Introduction
    • Section 356K – Overview of Part
  • ▸ Chapter 2 – Basic definitions
    • Section 356L – “Oil contractor activities” etc.
    • Section 356LA – “Relevant asset”
    • Section 356LB – “Associated person”
    • Section 356LC – “Lease”
    • Section 356LD – “Contractor’s ring fence profits”
  • ▸ Chapter 3 – Deemed separate trade
    • Section 356M – Oil contractor activities treated as separate trade
  • ▸ Chapter 4 – Calculation of profits
    • Hire of relevant assets
    • Loan relationships
    • Relief
    • Restriction on obtaining certain deductions
▸ Part 8ZB – Transactions in UK land
  • ▸ Introduction
    • Section 356OA – Overview of Part
  • ▸ Amounts treated as profits of a trade
    • Section 356OB – Disposals of land in United Kingdom
    • Section 356OC – Disposals of land: profits treated as trading profits
    • Section 356OD – Disposals of property deriving its value from land in the United Kingdom
    • Section 356OE – Disposals within section 356OD: profits treated as trading profits
    • Section 356OF – Profits and losses
  • ▸ Person to whom profits attributed
    • Section 356OG – The chargeable company
  • ▸ Anti-fragmentation
    • Section 356OH – Fragmented activities
  • ▸ Calculation of profit or gain on disposal
    • Section 356OI – Calculation of profit or gain on disposal
    • Section 356OJ – Apportionments
  • ▸ Arrangements for avoiding tax
    • Section 356OK – Arrangements for avoiding tax
  • ▸ Exemption
    • Section 356OL – Profits attributable to period before relevant activities etc began
  • ▸ Other supplementary provisions
    • Section 356OM – Tracing value
    • Section 356ON – Relevance of transactions, arrangements, etc
  • ▸ Interpretation
    • Section 356OO – "Another person"
    • Section 356OP – "Arrangement"
    • Section 356OQ – "Disposal"
    • Section 356OR – "Land" and related expressions
    • Section 356OS – References to realising a gain
    • Section 356OT – Related parties
▸ Part 8A – Profits arising from the exploitation of patents etc
  • ▸ Chapter 1 – Reduced corporation tax rate for profits from patents etc.
    • Section 357A – Election for special treatment of profits from patents etc.
  • ▸ Chapter 2 – Qualifying companies
    • Section 357B – Meaning of “qualifying company”
    • Section 357BA – Meaning of “exclusive licence”
    • Section 357BB – Rights to which this Part applies
    • Section 357BC – The development condition
    • Section 357BD – Meaning of “qualifying development”
    • Section 357BE – The active ownership condition
    • Section 357BBA – Rights to which this Part applies: EU rights
  • ▸ Chapter 2A – Relevant IP profits: cases mentioned in section 357A(6)
    • Steps for calculating relevant IP profits of a trade
    • Finance income
    • Relevant IP income
    • Excluded debits etc.
    • Routine return figure
    • Marketing assets return figure
    • R&D fraction
    • Profits arising before grant of right
    • Small claims treatment
  • ▸ Chapter 2B – Relevant IP profits: cases mentioned in section 357A(7): income from new IP
    • Section 357BO – Relevant IP profits
    • Section 357BP – Meaning of “new qualifying IP right” and “old qualifying IP right”
    • Section 357BQ – The modifications
  • ▸ Chapter 3 – Relevant IP profits
    • Steps for calculating relevant IP profits of a trade
    • Total gross income of trade
    • Relevant IP income
    • Calculating profits of trade
    • Routine return figure
    • Election for small claims treatment
    • Marketing assets return figure
    • Profits arising before grant of right
  • ▸ Chapter 4 – Streaming
    • Section 357D – Alternative method of calculating relevant IP profits: “streaming”
    • Section 357DA – Relevant IP profits
    • Section 357DB – Method of allocation
    • Section 357DC – The mandatory streaming conditions
  • ▸ Chapter 5 – Relevant IP losses
    • Section 357E – Company with relevant IP losses: set-off amount
    • Section 357EA – Effect of set-off amount on company with more than one trade
    • Section 357EB – Allocation of set-off amount within a group
    • Section 357EC – Carry-forward of set-off amount
    • Section 357ED – Company ceasing to carry on trade, etc.
    • Section 357EE – Transfer of a trade between group members
    • Section 357EF – Payments between group members in consequence of section 357EB
  • ▸ Chapter 6 – Anti-avoidance
    • Licences conferring exclusive rights
    • Incorporation of qualifying items
    • Tax advantage schemes
  • ▸ Chapter 7 – Supplementary
    • Elections under section 357A
    • Partnerships
    • Cost-sharing arrangements
    • Transferred trades
    • Interpretation
▸ Part 8B – Trading profits taxable at the Northern Ireland rate
  • ▸ Chapter 2 – The Northern Ireland rate
    • Section 357I – The Northern Ireland rate
    • Section 357IA – Power of Northern Ireland Assembly to set Northern Ireland rate
  • ▸ Chapter 9 – Research and development expenditure
    • Introductory
    • Chapter 1A – of Part 13 of CTA 2009
    • Chapter 2 – of Part 13 of CTA 2009
    • Chapter 7 – of Part 13 of CTA 2009
  • ▸ Chapter 8 – Intangible fixed assets
    • Introductory
    • Calculating Northern Ireland profits or Northern Ireland losses
    • Northern Ireland intangibles credits and Northern Ireland intangibles debits
    • Realisation credits and realisation debits
    • Pre-commencement assets
    • Assets treated as pre-commencement assets
    • Interpretation
  • ▸ Chapter 7 – Northern Ireland profits and losses etc: large companies
    • Introductory
    • Northern Ireland profits or losses and mainstream profits or losses
    • The separate enterprise principle
    • Rules about deductions and receipts
    • Supplementary
  • ▸ Chapter 6 – Northern Ireland profits and losses etc: SMEs
    • Section 357M – Introductory
    • Section 357MA – Northern Ireland profits or losses and mainstream profits or losses
    • Section 357MB – Profit imputed to back-office activities
  • ▸ Chapter 5 – Northern Ireland regional establishments
    • General
    • Circumstances where there is no NIRE
    • Brokers
    • Investment managers
    • Lloyd's agents
    • Supplementary
  • ▸ Chapter 4 – Basic definitions
    • Application of Chapter
    • Meaning of “Northern Ireland company”
    • Meaning of “qualifying trade”
    • Meaning of “SME”
    • Meaning of “Northern Ireland employer”
    • Meaning of “disqualified close company”
  • ▸ Chapter 3 – Northern Ireland rate applied to Northern Ireland profits and losses
    • Introductory
    • Profits chargeable to corporation tax and rates
    • Loss relief in relation to Northern Ireland profits and losses: Chapter 2 of Part 4
    • Loss relief in relation to Northern Ireland profits and losses: section 45
    • Loss relief in relation to Northern Ireland profits and losses: Part 5
    • Loss relief in relation to Northern Ireland profits and losses: Part 5A
    • Transfers of trade without a change of ownership: Chapter 1 of Part 22
    • Restricted deductions
  • ▸ Chapter 1 – Introductory
    • Section 357H – Introduction
  • ▸ Chapter 10 – Remediation of contaminated or derelict land
    • Introductory
    • Additional deduction under section 1149 of CTA 2009
    • Tax credit under section 1151 of CTA 2009
  • ▸ Chapter 11 – Film tax relief
    • Introductory
    • Film tax relief
    • Film losses
  • ▸ Chapter 12 – Television production
    • Introductory
    • Television tax relief
    • Programme losses
  • ▸ Chapter 13 – Video games development
    • Introductory
    • Video games tax relief
    • Video game losses
  • ▸ Chapter 14 – Theatrical productions
    • Introductory
    • Tax relief for theatrical productions
    • Use of losses
    • Provisional entitlement to relief
  • ▸ Chapter 15 – Profits arising from the exploitation of patents etc.
    • Introductory
    • Modification of deduction
    • “Relevant Northern Ireland IP profits”
    • Relevant IP losses
    • Interpretation
  • ▸ Chapter 16 – Northern Ireland profits and losses etc: partnerships
    • Section 357WBA – Northern Ireland workforce partnership conditions
    • Section 357WBB – Section 357WBA: supplementary
    • Section 357WBC – “Disqualified firm”
    • Section 357W – Introductory
    • Section 357WA – Meaning of “Northern Ireland firm”
    • Section 357WB – Meaning of “qualifying partnership trade”
    • Section 357WC – Northern Ireland profits etc. of firm determined under Chapter 6
    • Section 357WD – Northern Ireland profits etc. of firm determined under Chapter 7
    • Section 357WE – Sections 357WC and 357WD: interpretation
    • Section 357WF – Application of section 747 of CTA 2009 to Northern Ireland firm
    • Section 357WG – Application of Part 8A to Northern Ireland firm
    • Section 357WH – Allocation of Northern Ireland profits etc. of firm to company
  • ▸ Chapter 14A – Orchestra Tax Relief
    • Introductory
    • Orchestra tax relief
    • Losses of separate orchestral trade
  • ▸ Chapter 14B – Museums and galleries exhibition tax relief
    • Introductory
    • Museums and galleries exhibition tax relief
    • Losses of separate exhibition trade
  • ▸ Chapter 17 – Excluded trades, excluded activities and back-office activities
    • Introductory
    • Excluded trades
    • Excluded activities
    • Powers
  • ▸ Chapter 10A – Films, television programmes and video games qualifying for expenditure credit
    • Introduction
    • Expenditure credit
    • Losses of separate trade
▸ Part 8C – Restitution Interest
  • ▸ Chapter 1 – Amounts taxed as restitution interest
    • Section 357YA – Charge to corporation tax on restitution interest
    • Section 357YB – Restitution interest chargeable as income
    • Section 357YC – Meaning of “restitution interest”
    • Section 357YD – Further provision about amounts included, or not included, in “restitution interest”
    • Section 357YE – Period in which amounts are to be brought into account
    • Section 357YF – Companies without GAAP-compliant accounts
    • Section 357YG – Restitution interest: appeals made out of time
    • Section 357YH – Countering effect of avoidance arrangements
    • Section 357YI – Interpretation of section 357YH
    • Section 357YJ – Examples of results that may indicate exclusion not applicable
    • Section 357YDA – Life insurance companies: amounts representing policyholder income
  • ▸ Chapter 2 – Application of restitution payments rate
    • Section 357YK – Corporation tax rate on restitution interest
    • Section 357YL – Exclusion of reliefs, set-offs etc.
  • ▸ Chapter 3 – Migration, transfers of rights etc.
    • Section 357YM – Assignment of rights to person not chargeable to corporation tax
    • Section 357YN – Migration of company with claim to restitution interest
    • Section 357YNA – Transfer of rights: restitution interest arising after a winding up or dissolution
    • Section 357YNB – Meaning of “related company”
  • ▸ Chapter 4 – Payment and collection of tax on restitution interest
    • Section 357YO – Duty to deduct tax from payments of restitution interest
    • Section 357YP – Treatment of amounts deducted under section 357YO
    • Section 357YQ – Assessment of tax chargeable on restitution interest
    • Section 357YR – Interest on excessive amounts withheld
    • Section 357YS – Appeal against deduction
    • Section 357YT – Amounts taxed at restitution payments rate to be outside instalment payments regime
  • ▸ Chapter 5 – Supplementary provisions
    • Section 357YU – Interpretation
    • Section 357YV – Relationship of Part with other corporation tax provisions
    • Section 357YW – Power to amend
▸ Part 9 – Leasing plant or machinery
  • ▸ Chapter 1 – Introduction
    • Section 358 – Introduction to Part
  • ▸ Chapter 2 – Long funding leases of plant or machinery
    • Introduction
    • Lessors under long funding finance leases
    • Lessors under long funding operating leases
    • Cases where sections 360 to 369 do not apply
    • Lessees under long funding finance leases
    • Lessees under long funding operating leases
    • Interpretation
  • ▸ Chapter 3 – Sales of lessors: leasing business carried on by a company alone
    • Introduction
    • Income and matching expense in different accounting periods
    • “Business of leasing plant or machinery”
    • “Relevant change in relationship”
    • “Qualifying change of ownership”
    • Election out of qualifying change of ownership
    • The amount of the income
    • “Associated company”
  • ▸ Chapter 4 – Sales of lessors: leasing business carried on by a company in partnership
    • Introduction
    • “Business of leasing plant or machinery”
    • “Qualifying change” in company's interest in a business
    • Qualifying changes in partner company's interest in business
    • Qualifying changes of ownership in relation to partner company
    • Interpretation
  • ▸ Chapter 5 – Sales of lessors: anti-avoidance provisions
    • Section 432 – Restrictions on relief for Chapter 3 or 4 expenses: introduction
    • Section 433 – Restrictions applying to the restricted loss amount
    • Section 433A – Restrictions not applying to the restricted loss amount
    • Section 434 – Introduction to sections 435 and 436
    • Section 435 – Disregard of increases and decreases in certain amounts
    • Section 436 – Balance sheet amounts determined on assumption company has no liabilities
  • ▸ Chapter 6 – Sales of lessors: general interpretation
    • Section 437 – Interpretation of the sales of lessors Chapters
    • Section 437A – Determining the ascribed value of plant and machinery
    • Section 437B – Section 437A: supplementary
    • Section 437C – Present value of a lease
▸ Part 10 – Close companies
  • ▸ Chapter 1 – Overview of Part
    • Section 438 – Overview of Part
  • ▸ Chapter 2 – Basic definitions
    • Meaning of “close company": general
    • Companies which are not to be close companies
    • Meaning of other expressions in this Part
  • ▸ Chapter 3 – Charge to tax in case of loan to participator
    • Charge to tax in case of loan to participator
    • Exceptions to the charge to tax under section 455
    • Relief in case of repayment or release of loan
    • Loan treated as made to participator
    • Loan treated as made by close company
    • Taxation of debtor on release of loan to trustees of settlement which has ended
  • ▸ Chapter 3A – Charge to tax: other arrangements
    • Section 464A – Charge to tax: arrangements conferring benefit on participator
    • Section 464B – Relief in case of return payment to company
  • ▸ Chapter 3B – repayments and return payments
    • Section 464C – Treatment of certain repayments and return payments
    • Section 464D – Section 464C: supplementary
  • ▸ Chapter 4 – Power to obtain information
    • Section 465 – Power to obtain information
▸ Part 11 – Charitable companies etc
  • ▸ Chapter 1 – Introduction
    • Section 466 – Overview of Part
    • Section 467 – Meaning of “charitable company”
    • Section 468 – Meaning of “eligible body”
    • Section 469 – Conditions for qualifying as a scientific research association
    • Section 470 – Meaning of “research and development” in section 469
  • ▸ Chapter 2 – Gifts and other payments
    • Gifts and other payments to charitable companies
    • Gifts to eligible bodies
    • Gifts to scientific research associations
    • Claims
  • ▸ Chapter 3 – Other exemptions
    • Exemptions
    • Application of exemptions to certain bodies
    • Claims
  • ▸ Chapter 4 – Restrictions on exemptions
    • Restrictions on exemptions
    • Non-charitable expenditure
    • Substantial donor transactions
    • Approved charitable investments and loans
    • Carry back of excess non-charitable expenditure
▸ Part 12 – Real Estate Investment Trusts
  • ▸ Chapter 1 – Introduction
    • Introductory
    • Key concepts
  • ▸ Chapter 2 – Requirements for being a UK REIT
    • Becoming a UK REIT
    • Being a UK REIT in relation to an accounting period
  • ▸ Chapter 3 – Tax treatment of profits and gains of UK REITs
    • Section 534 – Profits
    • Section 535 – Gains
    • Section 535A – Gains: disposals of rights or interests in UK property rich companies
    • Section 535B – Section 535A: use of pre-April 2019 residual business losses or deficits
  • ▸ Chapter 4 – Entering the UK REIT regime
    • Section 536 – Effects of entry: corporation tax
    • Section 537 – Effects of entry: CAA 2001
    • Section 538 – Entry charge
    • Section 539 – Calculation of the notional amount
    • Section 540 – Election to treat notional income as arising in instalments
  • ▸ Chapter 5 – Assets etc.
    • Ring-fencing of property rental business
    • Profits: financing-cost ratio
    • Cancellation of tax advantage
    • Funds awaiting reinvestment
  • ▸ Chapter 6 – Distributions
    • Recipients of distributions
    • Attribution of distributions
    • Distributions to certain shareholders
  • ▸ Chapter 7 – Gains etc
    • Movement of assets
    • Demergers
    • Interpretation
  • ▸ Chapter 8 – Breach of conditions in Chapter 2
    • Section 561 – Notice of breach of relevant Chapter 2 condition
    • Section 562 – Breach of condition C in section 528 (conditions for company)
    • Section 562A – Breach of condition D in section 528 (conditions for company)
    • Section 562B – Breach of further condition relating to shares
    • Section 562C – Breach of further condition relating to shares in accounting periods 1, 2 and 3
    • Section 563 – Breach of property rental business condition
    • Section 564 – Breach of condition as to distribution of profits
    • Section 565 – “The section 565 amount”
    • Section 566 – Breach of condition B in section 531 in accounting period 1
    • Section 567 – Meaning of “the notional amount”
    • Section 568 – Breach of balance of business conditions after accounting period 1
    • Section 569 – Chapter subject to section 572
  • ▸ Chapter 9 – Leaving the UK REIT regime
    • Introduction
    • Notice to leave regime
    • Automatic termination
    • Effects of cessation
    • Early exit
  • ▸ Chapter 10 – Joint ventures
    • Introduction
    • Notice for Part to apply to joint venture
    • Effect and duration of notice
    • Specific requirements and modifications
    • Supplementary
  • ▸ Chapter 11 – Part 12: supplementary
    • Miscellaneous
    • Interpretation
▸ Part 13 – Other special types of company etc
  • ▸ Chapter 1 – Corporate beneficiaries under trusts
    • Discretionary payments
    • Trustees' expenses
  • ▸ Chapter 2 – Authorised investment funds
    • Introduction
    • Open-ended investment companies
    • Authorised unit trusts
    • Court investment funds
  • ▸ Chapter 3 – Unauthorised unit trusts
    • Section 621 – Treatment of income
    • Section 622 – Treatment of capital expenditure
  • ▸ Chapter 3A – Investment trusts
    • Section 622A – Power to make provision about treatment of transactions
  • ▸ Chapter 4 – Securitisation companies
    • Section 623 – Meaning of “securitisation company”
    • Section 624 – Power to make regulations about the taxation of securitisation companies
    • Section 625 – Regulations: supplementary
  • ▸ Chapter 5 – Companies in liquidation or administration
    • Introduction
    • Companies in liquidation
    • Companies in administration
    • Supplementary
  • ▸ Chapter 6 – Banks etc. in compulsory liquidation
    • Section 634 – Overview of Chapter
    • Section 635 – Application of Chapter
    • Section 636 – Charge to corporation tax on winding up receipts
    • Section 637 – Transfer of rights to payment
    • Section 638 – Allowable deductions
    • Section 639 – Election to carry back
    • Section 640 – Relationship of Chapter with other corporation tax provisions
    • Section 641 – Interpretation of Chapter
  • ▸ Chapter 7 – Co-operative housing associations
    • Section 642 – Disregard of rent from members and of interest payable
    • Section 643 – Exemption for gains on a sale of property
    • Section 644 – Approval of housing associations
    • Section 645 – Tests to be satisfied by the association
    • Section 646 – Delegation of powers to the Regulator of Social Housing
    • Section 647 – Claims under section 642 or 643
    • Section 648 – Adjustments of liability
    • Section 649 – Power to make further provision
  • ▸ Chapter 8 – Self-build societies
    • Section 650 – Meaning of “self-build society”
    • Section 651 – Disregard of rent from members
    • Section 652 – Exemption for gains on disposals of land to members
    • Section 653 – Approval of self-build societies
    • Section 654 – Delegation of powers to the Regulator of Social Housing
    • Section 655 – Claims under section 651 or 652
    • Section 656 – Adjustments of liability
    • Section 657 – Power to make further provision
  • ▸ Chapter 9 – Community amateur sports clubs
    • Basic concepts
    • Gifts ... relief
    • Exemptions
    • Claims
    • Restrictions on exemptions
    • Deemed disposal and acquisition of asset
    • Decisions and appeals
▸ Part 14 – Change in company ownership
  • ▸ Chapter 1 – Introduction
    • Section 672 – Overview of Part
  • ▸ Chapter 2 – Disallowance of trading losses
    • Section 673 – Introduction to Chapter
    • Section 674 – Disallowance of trading losses
    • Section 674A – Section 674: exception for certain losses of ring fence trade
    • Section 675 – Disallowance of trading losses: calculation of balancing charges
    • Section 676 – Company reconstructions
  • ▸ Chapter 2A – Post-1 April 2017 losses: Further cases involving a change in the company’s activities
    • Section 676AA – Introduction to Chapter
    • Section 676AB – Priority of provisions of Chapters 2 and 3 over this Chapter
    • Section 676AC – “Major change in the business” of a company
    • Section 676AD – Notional split of accounting period in which change in ownership occurs
    • Section 676AE – “Affected profits”
    • Section 676AF – Restriction on use of carried-forward post-1 April 2017 trade losses
    • Section 676AG – Restriction on debits to be brought into account
    • Section 676AH – Restriction on the carry forward of post-1 April 2017 non-trading deficit from loan relationships
    • Section 676AI – Restriction on relief for post-1 April 2017 non-trading loss on intangible fixed assets
    • Section 676AJ – Restriction on deduction of post-1 April 2017 expenses of management
    • Section 676AK – Restriction on use of post-1 April 2017 UK property business losses
    • Section 676AL – “Co-transferred company” and “related company”
  • ▸ Chapter 2B – Asset transferred within group: restriction of relief for post-1 April trade losses
    • Section 676BA – Introduction to Chapter
    • Section 676BB – Notional split of accounting period in which change in ownership occurs
    • Section 676BC – Disallowance of relief for trade losses
    • Section 676BD – Meaning of “the relevant provisions”
    • Section 676BE – Meaning of “amount of profits which represents a relevant gain”
  • ▸ Chapter 2C – Disallowance of group relief for carried-forward losses: general provision
    • Section 676CA – Introduction to Chapter
    • Section 676CB – Restriction on surrender of carried-forward losses
    • Section 676CC – Cases where consortium condition 1 or 2 was previously met
    • Section 676CD – Cases where consortium condition 3 or 4 was previously met
    • Section 676CE – Exceptions to restrictions
    • Section 676CF – Cases where Chapter 2, 2A or 3 also applies
    • Section 676CG – “Affected profits”
    • Section 676CH – “Relevant pre-acquisition loss”
    • Section 676CI – Interpretation of Chapter
  • ▸ Chapter 2D – Asset transferred within group: Restriction of group relief for carried-forward losses
    • Section 676DA – Introduction to Chapter
    • Section 676DB – Notional split of accounting period in which change in ownership occurs
    • Section 676DC – Disallowance of group relief for carried-forward losses
    • Section 676DD – Meaning of “the relevant provisions”
    • Section 676DE – Meaning of “amount of profits which represents a relevant gain”
  • ▸ Chapter 2E – Post-1 April 2017 trade losses: cases involving the transfer of a trade
    • Section 676EA – Introduction to Chapter
    • Section 676EB – Restriction on use of trade losses carried-forward on transfer of trade
    • Section 676EC – Restriction on surrender of trade losses carried forward on transfer of trade
    • Section 676ED – Indirect transfers of a trade
    • Section 676EE – Interpretation of Chapter
  • ▸ Chapter 3 – Company with investment business: restrictions on relief: general provision
    • Introduction
    • Notional split of accounting period in which change in ownership occurs
    • Restrictions on relief
    • Apportionment of amounts
    • Adjustment to balancing charges if relief is restricted
    • Meaning of “significant increase in the amount of a company's capital”
  • ▸ Chapter 4 – Company with investment business: restrictions on relief: asset transferred within group
    • Introduction
    • Notional split of accounting period in which change in ownership occurs
    • Restrictions on relief
    • Apportionment of amounts
  • ▸ Chapter 5 – Company without investment business: disallowance of property losses
    • Section 704 – Company carrying on UK property business
    • Section 705 – Company carrying on overseas property business
  • ▸ Chapter 5A – Shell companies: restrictions on relief
    • Introduction
    • Restrictions on relief
    • Apportionment of amounts
  • ▸ Chapter 6 – Recovery of unpaid corporation tax
    • General definitions
    • Recovery of unpaid corporation tax for accounting period beginning before change
    • Recovery of unpaid corporation tax for accounting period ending on or after change
    • Miscellaneous
  • ▸ Chapter 7 – Meaning of “change in the ownership of a company”
    • Meaning of “change in the ownership of a company”
    • Changes in indirect ownership
    • Disregard of change in ownership
    • Supplementary provision
  • ▸ Chapter 8 – Supplementary provision
    • Section 727 – Extended time limit for assessment
    • Section 728 – Provision of information about ownership of shares etc
    • Section 729 – Meaning of “company with investment business”
    • Section 730 – Meaning of “relevant non-trading debit”
▸ Part 14A – Transfer of deductions
  • Section 730A – Overview
  • Section 730B – Interpretation of Part
  • Section 730C – Disallowance of deductible amounts: relevant claims
  • Section 730D – Disallowance of deductible amounts: profit transfers
▸ Part 14B – Tax avoidance involving carried-forward losses
  • Section 730E – Overview
  • Section 730F – Meaning of “relevant carried-forward loss”
  • Section 730G – Disallowance of deductions for relevant carried-forward losses
  • Section 730H – Interpretation of section 730G
▸ Part 15 – Transactions in securities
  • ▸ Introduction
    • Section 731 – Overview of Part
    • Section 732 – Meaning of “corporation tax advantage”
  • ▸ Company liable to counteraction of corporation tax advantage
    • Section 733 – Company liable to counteraction of corporation tax advantage
    • Section 734 – Exception where no tax avoidance object shown
  • ▸ Circumstances in which corporation tax advantages obtained or obtainable
    • Section 735 – Abnormal dividends used for exemptions or reliefs (circumstance A)
    • Section 736 – Receipt of consideration representing company’s assets, future receipts or trading stock (circumstance C)
    • Section 737 – Receipt of consideration in connection with relevant company distribution (circumstance D)
    • Section 738 – Receipt of assets of relevant company (circumstance E)
    • Section 739 – Meaning of “relevant company” in sections 737 and 738
    • Section 740 – Abnormal dividends: general
    • Section 741 – Abnormal dividends: the excessive return condition
    • Section 742 – Abnormal dividends: the excessive accrual condition
  • ▸ Procedure for counteraction of corporation tax advantages
    • Section 743 – Preliminary notification that section 733 may apply
    • Section 744 – Opposed notifications: statutory declarations
    • Section 745 – Opposed notifications: determinations by tribunal
    • Section 746 – Counteraction notices
    • Section 747 – Timing of assessments in section 738 cases
  • ▸ Clearance procedure
    • Section 748 – Application for clearance of transactions
    • Section 749 – Effect of clearance notification under section 748
  • ▸ Appeals
    • Section 750 – Appeals against counteraction notices
  • ▸ Interpretation
    • Section 751 – Interpretation of Part
▸ Part 16 – Factoring of income etc.
  • ▸ Chapter 1 – Transfers of income streams
    • Section 752 – Application of Chapter
    • Section 753 – Value of transferred income stream treated as income
    • Section 754 – Exception: amount otherwise taxed
    • Section 755 – Exception: transfer by way of security
    • Section 756 – Partnership shares
    • Section 757 – Interpretation of Chapter
  • ▸ Chapter 1A – Disposals of income streams through partnerships
    • Section 757A – Application of Chapter
    • Section 757B – Relevant amount to be treated as income
  • ▸ Chapter 2 – Finance arrangements
    • Type 1 arrangements
    • Type 2 arrangements
    • Type 3 arrangements
    • Exceptions
    • Supplementary
  • ▸ Chapter 3 – Loan or credit transactions
    • Section 777 – Loan or credit transaction defined
    • Section 778 – Certain payments treated as interest
    • Section 779 – Tax charged on income transferred
  • ▸ Chapter 4 – Disposals of assets through partnerships
    • Section 779A – Application of Chapter
    • Section 779B – Relevant amount to be treated as income
▸ Part 17 – Manufactured payments and repos
  • ▸ Chapter 1 – Introduction
    • Section 780 – Overview of Part
    • Section 781 – Key definitions
  • ▸ Chapter 2 – Manufactured dividends
    • Section 782 – Meaning of “manufactured dividend”
    • Section 783 – Treatment of payer of manufactured dividend
    • Section 784 – Treatment of recipient of manufactured dividend
    • Section 785 – Treatment of payer: Real Estate Investment Trusts
    • Section 786 – Treatment of recipient: Real Estate Investment Trusts
    • Section 787 – Exemption of manufactured dividends
    • Section 788 – Statements about manufactured dividends
    • Section 789 – Powers about administrative provisions
  • ▸ Chapter 3 – Manufactured overseas dividends
    • Section 790 – Meaning of “manufactured overseas dividend”
    • Section 791 – Treatment of payer of manufactured overseas dividend
    • Section 792 – Company receiving manufactured overseas dividend from UK resident etc
    • Section 793 – Section 792: amount treated as withheld
    • Section 794 – Company receiving manufactured overseas dividend from foreign payer
    • Section 795 – Exemption of manufactured overseas dividends
  • ▸ Chapter 4 – Further provision about manufactured payments
    • Manufactured payments exceeding, or less than, underlying payments
    • Manufactured payments under arrangements with unallowable purpose
    • Miscellaneous
  • ▸ Chapter 5 – Stock lending arrangements and repos
    • Interpretation
    • Tax credits: stock lending arrangements and repos
    • Deemed manufactured payments
  • ▸ Chapter 6 – Interpretation of Part
    • Section 813 – The gross amount of a manufactured overseas dividend etc
    • Section 814 – Other interpretation
▸ Part 17A – Manufactured dividends
  • Section 814A – Overview of Part
  • Section 814B – Key definitions
  • Section 814C – Treatment of payer of manufactured dividend
  • Section 814D – Treatment of recipient of manufactured dividend
▸ Part 18 – Transactions in land
  • ▸ Introduction
    • Section 815 – Introduction to Part
    • Section 816 – Meaning of disposing of land
    • Section 817 – Priority of other tax provisions
  • ▸ Charge to tax on gains from transactions in land
    • Section 818 – Charge to tax on gains from transactions in land
    • Section 819 – Gains obtained from land disposals in some circumstances
    • Section 820 – Person obtaining gain
    • Section 821 – Company chargeable
    • Section 822 – Method of calculating gain
  • ▸ Further provisions relevant to the charge
    • Section 823 – Transactions, arrangements, sales and realisations relevant for Part
    • Section 824 – Tracing value
    • Section 825 – Meaning of “another person”
    • Section 826 – Valuations and apportionments
  • ▸ Exemptions
    • Section 827 – Gain attributable to period before intention to develop formed
    • Section 828 – Disposals of shares in companies holding land as trading stock
  • ▸ Recovery of tax
    • Section 829 – Cases where consideration receivable by person not assessed
    • Section 830 – Certificates of tax paid etc.
  • ▸ Clearances and power to obtain information
    • Section 831 – Clearance procedure
    • Section 832 – Power to obtain information
  • ▸ Interpretation
    • Section 833 – Interpretation of Part
▸ Part 19 – Sale and lease-back etc
  • ▸ Chapter 1 – Payments connected with transferred land
    • Introduction
    • Application of the Chapter
    • Relief (other than for certain insurance company expenses): restriction and carrying forward
    • Insurance company expenses: restriction and carrying forward of relief
    • Interpretation etc.
  • ▸ Chapter 2 – New lease of land after assignment or surrender
    • Introduction
    • Application of the Chapter
    • Taxation of consideration
    • Relief for rent under new lease
    • New lease treated as ending
    • Lease varied to provide for increased rent
    • Interpretation
  • ▸ Chapter 3 – Leased trading assets
    • Introduction
    • Application of the Chapter
    • Relief: restriction and carrying forward
    • Interpretation
  • ▸ Chapter 4 – Leased assets: capital sums
    • Introduction
    • Application of the Chapter
    • Charge to corporation tax
    • Obtaining of sum
    • Apportionment
    • Interpretation
▸ Part 20 – Tax avoidance involving leasing plant or machinery
  • ▸ Chapter 1 – Restrictions on use of losses in leasing partnerships
    • Section 887 – When restrictions on leasing partnership losses under this Chapter apply
    • Section 888 – Restrictions on leasing partnership losses
    • Section 889 – Interpretation of Chapter
  • ▸ Chapter 2 – Capital payments in respect of leases treated as income
    • Section 890 – Capital payments in respect of leases treated as income
    • Section 891 – Apportionments for leases of plant or machinery and other property
    • Section 892 – Deduction where failure to make relevant capital payment expected
    • Section 893 – Meaning of “capital payment”, “relevant capital payment” etc
    • Section 894 – Other interpretation of Chapter
  • ▸ Chapter 3 – Consideration for taking over payment obligations as lessee treated as income
    • Section 894A – Consideration for taking over payment obligations as lessee treated as income
▸ Part 21 – Leasing arrangements: finance leases and loans
  • ▸ Chapter 1 – Introduction
    • Introduction
    • Meaning of expressions about rent
  • ▸ Chapter 2 – Finance leases with return in capital form
    • Introduction
    • Leases to which this Chapter applies
    • Current lessor taxed by reference to accountancy rental earnings
    • Reduction of taxable rent by cumulative rental excesses
    • Relief for bad debts by reduction of cumulative rental excesses
    • Effect of disposals
    • Capital allowances: clawback of major lump sum
    • Schemes to which this Chapter does not at first apply
  • ▸ Chapter 3 – Other finance leases
    • Introduction
    • Current lessor taxed by reference to accountancy rental earnings
    • Application of provisions of Chapter 2 for purposes of this Chapter
  • ▸ Chapter 4 – Supplementary provisions
    • Section 930 – Pre-26 November 1996 schemes and post-25 November 1996 schemes
    • Section 931 – Time apportionment where periods of account do not coincide
    • Section 932 – Periods of account and related periods of account and accounting periods
    • Section 933 – Connected persons
    • Section 934 – Assets which represent the leased asset
    • Section 935 – Parent undertakings and consolidated group accounts
    • Section 936 – Assessments and adjustments
    • Section 937 – Interpretation of Part
▸ Part 21A – Risk transfer schemes
  • ▸ Introduction
    • Section 937A – Overview
    • Section 937B – Group schemes and single company schemes
  • ▸ Basic definitions
    • Section 937C – Meaning of “risk transfer scheme”
    • Section 937D – Meaning of “the scheme rate, index or value”
    • Section 937E – Scheme losses and scheme profits
    • Section 937F – Ring-fenced scheme losses and relevant scheme profits
  • ▸ Treatment of ring-fenced scheme losses
    • Section 937G – Ring-fenced scheme loss: treatment in period in which made
    • Section 937H – Ring-fenced scheme loss: treatment in subsequent periods
  • ▸ A company's losses pool and profits pool
    • Section 937I – A company’s losses pool and profits pool
  • ▸ General
    • Section 937J – Tax capacity assumption
    • Section 937K – Meaning of “associated with”
    • Section 937L – Interpretation of references to economic losses and profits
    • Section 937M – Foreign currency accounting
    • Section 937N – Meaning of “scheme”
    • Section 937NA – Priority
  • ▸ Power to amend this Part
    • Section 937O – Power to amend this Part in its application to dealers in securities
▸ Part 21B – Group Mismatch Schemes
  • Section 938A – Losses and profits from group mismatch schemes to be disregarded
  • Section 938B – Meaning of “a group mismatch scheme” and “the scheme group”
  • Section 938C – Meaning of “scheme loss” and “scheme profit”
  • Section 938D – Meaning of “relevant tax advantage” etc. and “the scheme period”
  • Section 938E – Meaning of “group”
  • Section 938F – Meaning of references to economic profits and losses
  • Section 938G – Tax capacity assumption
  • Section 938H – Meaning of “scheme”
  • Section 938I – Schemes involving repos or quasi-repos
  • Section 938J – Schemes involving finance arrangements
  • Section 938K – Trading income
  • Section 938L – Foreign companies and foreign permanent establishments
  • Section 938M – Controlled foreign companies
  • Section 938N – Priority
▸ Part 21BA – Tax mismatch schemes
  • Section 938O – Losses and profits from tax mismatch scheme to be disregarded
  • Section 938P – Meaning of “tax mismatch scheme”
  • Section 938Q – Meaning of “scheme loss” and “scheme profit”
  • Section 938R – Meaning of “relevant tax advantage” etc. and “the scheme period”
  • Section 938S – Meaning of references to economic profits and losses
  • Section 938T – Tax capacity assumption
  • Section 938U – Meaning of “scheme”
  • Section 938V – Priority
▸ Part 21C – Tainted charity donations
  • ▸ Introduction
    • Section 939A – Overview of Part
    • Section 939B – Relievable charity donations
  • ▸ Tainted donations
    • Section 939C – Tainted donations
    • Section 939D – Circumstances in which financial advantage deemed to be obtained
    • Section 939E – Certain financial advantages to be ignored
  • ▸ Removal of reliefs
    • Section 939F – Removal of corporation tax relief in respect of tainted donations etc.
  • ▸ Supplementary
    • Section 939G – Connected charities
    • Section 939H – Connected persons
    • Section 939I – Minor definitions
▸ Part 22 – Miscellaneous provisions
  • ▸ Chapter 1 – Transfers of trade without a change of ownership
    • Introduction
    • Transfers to which Chapter applies
    • Effect of Chapter in relation to transfers to which it applies
    • Supplementary
  • ▸ Chapter 2 – Transfers of trade to obtain balancing allowances
    • Section 954 – Transfer of activities on complete cessation of trade
    • Section 955 – Transfer of activities on part cessation of trade
    • Section 956 – Apportionment if part of trade treated as separate trade
    • Section 957 – Chapter 2: supplementary
  • ▸ Chapter 3 – Transfer of relief within partnerships
    • Section 958 – Application
    • Section 959 – Arrangements for transfer of relief
    • Section 960 – Restrictions on use of reliefs
    • Section 961 – Non-trading profits and losses
    • Section 962 – Interpretation of Chapter
  • ▸ Chapter 4 – Surrender of tax refund within group
    • Section 963 – Power to surrender tax refund
    • Section 964 – Effects of surrender of tax refund
    • Section 965 – Interest on tax overpaid or underpaid
    • Section 966 – Payments for surrendered tax refunds
  • ▸ Chapter 5 – Set off of income tax deductions against corporation tax
    • Section 967 – Deductions from payments received by UK resident companies
    • Section 968 – Deductions from payments received by non-UK resident companies
  • ▸ Chapter 6 – Collection etc. of tax from UK representatives of non-UK resident companies
    • Section 969 – Introduction to Chapter
    • Section 970 – Obligations and liabilities in relation to corporation tax
    • Section 971 – Exceptions
    • Section 972 – Interpretation of Chapter
  • ▸ Chapter 7 – Recovery of unpaid corporation tax due from non-UK resident company
    • Section 973 – Introduction to Chapter
    • Section 974 – Case in which this Chapter applies
    • Section 975 – Meaning of “the relevant period”
    • Section 976 – Meaning of “related company”
    • Section 977 – Notice requiring payment of unpaid tax
    • Section 978 – Time limit for giving notice
    • Section 979 – Amount payable in consortium case
    • Section 980 – Chapter 7: supplementary
  • ▸ Chapter 8 – Exemptions
    • Trade unions and employers' associations
    • Local authorities etc.
    • Health service bodies
    • Police
    • Education Authority of Northern Ireland
    • Northern Ireland Housing Executive
    • Reserve Bank of India and State Bank of Pakistan
    • Agricultural societies
  • ▸ Chapter 9 – Other miscellaneous provisions
    • UK Economic Interest Groupings and European Economic Interest Groupings
    • Harbour reorganisation schemes
    • Groups: use of different accounting practices
    • Sporting testimonial payments and associated payments
▸ Part 23 – Company distributions
  • ▸ Chapter 1 – Introduction
    • Section 997 – Overview of Part
  • ▸ Chapter 2 – Matters which are distributions
    • Introduction
    • Meaning of “distribution”
    • Distributions, other than dividends, in respect of shares
    • Redeemable share capital
    • Securities issued otherwise than for new consideration
    • Distributions in respect of non-commercial securities
    • Exceptions to section 1008
    • Distributions in respect of special securities
    • Transfers of assets or liabilities treated as distributions
    • Bonus issue following repayment of share capital
    • Interpretation of references to repayment of share capital
  • ▸ Chapter 3 – Matters which are not distributions
    • Introduction
    • Distributions in a winding up
    • Distributions prior to dissolution of company
    • Distribution as part of a cross-border merger
    • Payments of interest
    • Purchase of own shares
    • Purchase of own shares: supplementary
    • Stock dividends
    • Building society payments
    • Registered society payments
    • Payments made by UK agricultural or fishing co-operatives
    • Supplementary provisions
  • ▸ Chapter 4 – Special rules for distributions made by certain companies
    • Close companies
    • Companies carrying on a mutual business
    • Companies not carrying on a business
    • Members of a 90% group
  • ▸ Chapter 5 – Demergers
    • Introduction
    • Exempt distributions
    • Exemption by virtue of section 1076 or 1077: conditions
    • Chargeable payments
    • Advance clearance
    • Information and returns
    • Supplementary
  • ▸ Chapter 6 – Information and returns: further provisions
    • General duties to provide information
    • Companies and nominees required to provide tax certificates
  • ▸ Chapter 7 – Tax credits
    • Section 1109 – Tax credits for certain recipients of exempt qualifying distributions
    • Section 1110 – Recovery of overpaid tax credit etc
    • Section 1111 – Section 1110: supplementary
  • ▸ Chapter 8 – Interpretation of Part
    • Section 1112 – Arrangements between companies
    • Section 1113 – “In respect of shares”
    • Section 1114 – “In respect of securities”
    • Section 1115 – “New consideration”
    • Section 1116 – References to married persons, or civil partners, living together
    • Section 1117 – Other interpretation
▸ Part 24 – Corporation Tax Acts definitions etc
  • ▸ Chapter 1 – Definitions
    • Section 1129 – “Hire-purchase agreement”
    • Section 1140 – “Unauthorised unit trust”
    • Section 1139 – “Tax advantage”
    • Section 1138 – “Research and development”
    • Section 1137 – “Recognised stock exchange”
    • Section 1136 – “Qualifying distribution”
    • Section 1135 – “Property investment LLP”
    • Section 1134 – “Oil and gas exploration and appraisal”
    • Section 1133 – Regulations about the meaning of “offshore installation”
    • Section 1132 – “Offshore installation”
    • Section 1131 – “Local authority association”
    • Section 1130 – “Local authority”
    • Section 1118 – Introduction to Chapter
    • Section 1128 – “Grossing up”
    • Section 1127 – “Generally accepted accounting practice” and related expressions
    • Section 1126 – “Franked investment income”
    • Section 1125 – “Farming” and related expressions
    • Section 1124 – “Control”
    • Section 1123 – “Connected” persons: supplementary
    • Section 1122 – “Connected” persons
    • Section 1121 – “Company”
    • Section 1120 – “Bank”
    • Section 1119 – The definitions
  • ▸ Chapter 2 – Permanent establishments
    • General
    • Circumstances where there is no permanent establishment
    • Brokers
    • Investment managers
    • Lloyd's agents
    • Supplementary
  • ▸ Chapter 3 – Subsidiaries
    • Section 1154 – Meaning of “51% subsidiary”, “75% subsidiary” and “90% subsidiary”
    • Section 1155 – Indirect ownership of ordinary share capital
    • Section 1156 – Calculation of amounts owned indirectly: main rules
    • Section 1157 – Adding fractions together
  • ▸ Chapter 4 – Investment trusts
    • Section 1158 – Meaning of “investment trust”
    • Section 1159 – Approval
    • Section 1160 – Calculation of income
    • Section 1161 – The income retention condition: exceptions
    • Section 1162 – The 15% holding limit: exceptions
    • Section 1163 – Basic meaning of “holding in a company”
    • Section 1164 – More about the meaning of “holding in a company”
    • Section 1165 – Other interpretation
  • ▸ Chapter 5 – Other Corporation Tax Acts provisions
    • Section 1166 – Scotland
    • Section 1167 – Sources of income within the charge to corporation tax or income tax
    • Section 1168 – Payment of dividends
    • Section 1169 – Settlements and trustees
    • Section 1170 – Territorial sea of the United Kingdom
    • Section 1171 – Orders and regulations
    • Section 1172 – Apportionment to different periods
    • Section 1173 – Miscellaneous charges
▸ Part 25 – Definitions for purposes of Act and final provisions
  • ▸ Definitions for the purposes of Act
    • Section 1174 – Abbreviated references to Acts
    • Section 1175 – Claims and elections
    • Section 1176 – Meaning of “connected” persons and “control”
  • ▸ Final provisions
    • Section 1177 – Minor and consequential amendments
    • Section 1178 – Power to make consequential provision
    • Section 1179 – Power to undo changes
    • Section 1180 – Transitional provisions and savings
    • Section 1181 – Repeals and revocations
    • Section 1182 – Index of defined expressions
    • Section 1183 – Extent
    • Section 1184 – Commencement
    • Section 1185 – Short title
Part 6 – Charitable donations relief / Chapter 3 – Certain disposals to charity / Interpretation

Interpretation

Contents

  • Section 217 – “Charity” Section commentary

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