Corporation Tax Act 2010 section 184

References to "allowance" in CAA 2001

Section 184 clarifies how the term "allowance" in the Capital Allowances Act 2001 should be interpreted where capital allowances have been surrendered as group relief.

  • References to an "allowance" in the Capital Allowances Act 2001 (excluding Parts 6 and 10) include allowances that would have been made but for group relief being given.
  • This also covers allowances that would have been made but for both the giving of group relief and a lack of profits or other income.
  • Capital allowances surrendered as group relief are still treated as having been made to the surrendering company.
  • This ensures that any subsequent balancing charge on the surrendering company properly takes into account the allowances it surrendered to other group members.

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