Corporation Tax Act 2010 section 689

Amount A

Section 689 defines "Amount A" for the purposes of determining whether there has been a significant increase in a company's capital, by comparing the company's capital immediately before a change in ownership with a measure of its sustained capital level over the preceding year.

• Amount A is the lower of the company's capital immediately before the change in ownership and the highest 60-day minimum amount for the pre-change year.
• The highest 60-day minimum amount is found by reviewing the daily capital amounts over the year before the ownership change and identifying the highest amount that was sustained without any dip for at least 60 consecutive days.
• If the highest daily amount was not maintained for 60 days, you work downwards through successively lower daily amounts until you find one that was sustained for at least 60 days.
• The "pre-change year" is defined as the one-year period ending immediately before the change in ownership.