Corporation Tax Act 2010 section 192

Condition as to repayment

Section 192 sets out the conditions under which a charitable payment made by a wholly-owned subsidiary to its parent charity is not treated as being subject to a repayment condition, even if the charity later returns some of the money to adjust the amount.

• The company must be wholly owned by the charity (or by a group of charities that includes the charity receiving the payment).
• The charitable payment must be the company's estimate of the amount needed to reduce its taxable total profits to nil for the accounting period in which the payment is made.
• Any repayment by the charity to the company must be made solely to correct the original estimate, so that the net payment matches the actual amount needed to reduce the company's taxable profits to nil.
• The repayment must be made no later than 12 months after the end of the accounting period in which the charitable payment was made.