Corporation Tax Act 2010 section 667

Rules for attributing surplus amount to earlier periods etc

Section 667 sets out the rules governing how surplus non-qualifying expenditure of a community amateur sports club is attributed back to reduce exemptions claimed in earlier accounting periods.

• Surplus non-qualifying expenditure can only reduce exemptions in earlier periods that ended no more than six years before the end of the current accounting period.
• Where multiple earlier periods are affected, reductions are applied to the most recent periods first, working backwards.
• An exemption that has already been reduced for non-qualifying expenditure in one accounting period cannot be reduced again for non-qualifying expenditure arising in a later period.
• HMRC must make any necessary adjustments, including issuing assessments, to give effect to these reductions in earlier periods.