Corporation Tax Act 2010 section 356OJ

Apportionments

Section 356OJ requires that any apportionment of expenditure, consideration, or other amounts under this Part of the Act must be carried out on a just and reasonable basis.

• Applies to all apportionments required under this Part of the Act, whether of expenditure, consideration, or any other amount.
• The overriding principle is that every apportionment must be made on a just and reasonable basis.
• No specific formula or method is prescribed — professional judgement is required to determine what is fair in each case.
• The requirement acts as a safeguard against arbitrary or tax-motivated allocations of costs and receipts.