Corporation Tax Act 2010 section 730B

Interpretation of Part

Section 730B defines the key terms used throughout Part 14A (Transfer of Deductions), including "deductible amount", "qualifying change", "arrangements" and what it means to bring an amount into account "as a deduction".

• A "deductible amount" covers trade expenses, property business expenses, investment management expenses, and certain non-trading debits from loan relationships, derivative contracts and intangible fixed assets — but excludes research and development allowances treated as trade expenses and amounts already factored into the relevant tax written-down value under the allowance-buying rules.
• "Arrangements" is defined very broadly to include any agreement, understanding, scheme, transaction or series of transactions, whether or not legally enforceable.
• A "qualifying change" in relation to a company has the same meaning as in the capital allowances anti-avoidance rules on allowance buying, and "the relevant day" is the day on which that qualifying change occurred.
• Bringing an amount into account "as a deduction" means using it either in calculating profits, losses or other amounts for corporation tax purposes, or as a deduction from profits or other amounts that are chargeable to corporation tax.