Corporation Tax Act 2010 section 203

Certain disposals of investments

Section 203 sets out the conditions under which a company can obtain corporation tax relief when it disposes of a qualifying investment to a charity at less than market value.

• Relief applies where a company transfers the whole beneficial interest in a qualifying investment to a charity otherwise than at arm's length, provided the company is not itself a charity and makes a claim.
• The relievable amount is treated as a qualifying charitable donation in the accounting period of the disposal, giving the company corporation tax relief.
• Where relief is given under this section, no separate relief can be claimed under CTA 2009 section 105 for gifts of trading stock to charities, even if the investment might otherwise qualify as trading stock.
• Where the qualifying investment is an interest in land, additional rules apply covering certificates, jointly held interests, joint disposal calculations, and disqualifying events.