Corporation Tax Act 2010 section 269DJ

Surcharge allowance for company not in a group containing other banking companies

Section 269DJ sets out how the banking surcharge allowance works for a banking company that is either not part of a group or is not in a group that contains other banking companies.

  • A standalone banking company (or one not grouped with other banking companies) has an available surcharge allowance of £25,000,000 per 12-month accounting period
  • The company must specify the amount of surcharge allowance it wishes to use in its corporation tax return
  • If the accounting period is shorter than 12 months, the £25,000,000 allowance is reduced proportionally
  • The combined total of the surcharge allowance claimed in the tax return and any amount set against controlled foreign company (CFC) apportioned profits must not exceed the available surcharge allowance for the period

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