Corporation Tax Act 2010 section 356ND

Management expenses

Section 356ND prohibits a contractor from deducting investment business management expenses against its ring fence profits.

• Companies can normally deduct expenses of managing their investment business under section 1219 of the Corporation Tax Act 2009.
• This section blocks that deduction where the profits in question are ring fence profits of a contractor.
• Ring fence profits must be kept separate and cannot be reduced by investment management costs.
• The restriction ensures that ring fence profits are preserved from erosion by unrelated management expenses.