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Company Taxation Manual
Publication Date:
2025
Publisher:
Bloomsbury Professional
Copyright:
2025 Crown
Company Taxation Manual
All aspects of company taxation.
Last update
: 28th February 2025
GO
Contents
Contents
Expand All
Collapse All
Close section
CTM00200: Destination & derivation tables for CT to CTM conversion
Close section
CTM00210: Destination tables on conversion from CT to CTM
CTM00211: Destination table for pages CT1-CT1765 & Preface
CTM00212: Destination table for pages CT1800-CT2925
CTM00213: Destination table for pages CT2990-CT3689
CTM00214: Destination table for pages CT3800-CT4762
CTM00215: Destination table for pages CT6000-CT9696
CTM00216: Destination table for pages CT10000-CT11520 & Lists 1/2
CTM00217: Destination table for pages CT12000-CT13085
CTM00218: Destination table for pages CT13200-CT13723
CTM00219: Destination table for pages CT13730-CT14210
Close section
CTM00220: Derivation tables for pages in the CTM converted from the CT
CTM00221: Derivation table for pages CTM00500 - CTM18850
CTM00222: Derivation table for pages CTM20000 - CTM22360
CTM00223: Derivation table for pages CTM34000 - CTM 36890
CTM00224: Derivation table for pages CTM40000 - CTM 49650
CTM00225: Derivation table for pages CTM50000 - CTM 59815
CTM00226: Derivation table for pages CTM60000 - CTM61790
CTM00227: Derivation table for pages CTM70000 - CTM 79930
CTM00228: Derivation table for pages CTM80000 - CTM81280
CTM00229: Derivation table for pages CTM90000 - CTM98265
Close section
CTM00500: Introductory: contents
CTM00505: Preface
CTM00509: Important Terms
CTM00520: Concerns within the charge to CT
CTM00530: Company officers
CTM00550: Abbreviations used
CTM00560: Accountancy help
CTM00570: Feedback and technical guidance
Close section
CTM01000: Corporation Tax
Close section
CTM01100: Introduction
CTM01105: Basis of charge to CT
CTM01110: Definition of company profits
CTM01120: Profits from trusts and partnerships
CTM01130: Computation of profits
CTM01140: Charitable donations relief: formerly charges on income
CTM01150: Application of IT exemptions
CTM01160: Distributions
CTM01170: IT deducted from income received
CTM01180: IT deduction from certain payments
CTM01190: Close companies
Close section
CTM01400: Accounting periods
CTM01405: Apportionment
CTM01410: Commencement
CTM01420: Commencement - special cases
CTM01500: End
CTM01510: Cannot exceed 12 months
CTM01515: Companies in administration
CTM01520: Company winding-up
CTM01530: Two or more trades
CTM01550: Insufficient information to determine
CTM01560: Accounts made up to slightly varying dates
CTM01750: Rates of tax
CTM01800: Due date of payment
Close section
CTM02000: Computation of income
CTM02010: Broad principles
CTM02020: IT law: pre Tax Law Rewrite
CTM02030: CTA09 and CTA10
CTM02040: Provisions common to IT and CT
CTM02050: Dividends and other distributions made
CTM02060: Dividends and other distributions received
CTM02100: Special rules - commencement and cessation of trade
CTM02110: Special rules - grant relief in Northern Ireland
CTM02120: Special rules - mineral rights
CTM02130: Special rules - trades abroad charged under Case V
CTM02140: Directors fees received by companies
CTM02150: Directors fees received by companies - assessment
CTM02250: Chargeable gains
CTM02350: Capital allowances
Close section
CTM03500: Small profits relief
CTM03505: Introduction
CTM03510: Rates, limits & fractions
CTM03520: The starting rate - financial years 2000 to 2005
CTM03530: No associated companies - profits not exceeding the lower limit
CTM03540: No associated companies - profits exceeding the lower limit
CTM03550: No associated companies - accounting period less than 12 months
CTM03560: Company with associated companies
CTM03570: Associated company - definition
CTM03580: Associated company - main rules of association
CTM03590: Whether trade or business carried on - decided cases
CTM03591: Whether trade or business carried on - business compared with trade
CTM03592: Whether trade or business carried on - investment and holding companies
CTM03600: Definition of augmented profits
CTM03640: Accounting period straddling financial year - differing relevant amounts or limits
CTM03650: Examples - summary
CTM03653: Example 1
CTM03654: Example 2
CTM03655: Example 3
CTM03670: Administrative
CTM03710: Associated companies - detailed provisions - introduction
CTM03730: Control by the same person or persons
CTM03740: Attribution of rights and powers of nominees
CTM03750: Attribution of rights and powers of associates
CTM03755: Attribution of rights and powers of associates - guidance applying to accounting periods ending before 1/4/2011
CTM03760: ESC C9
CTM03765: ESC C9 - full text
CTM03770: Substantial commercial interdependence: contents
CTM03805: Association through a loan creditor
CTM03810: Association by holding fixed rate preference shares
CTM03830: Association through a trustee
CTM03850: Risk assessment
Close section
CTM03900: Small profits rate: Financial year 2023 onwards
CTM03905: Introduction
CTM03910: Rates, limits and fractions
CTM03915: Definition of augmented profits
CTM03920: Associated companies: Profits not exceeding the lower limit
CTM03925: No associated companies: Profits exceeding the lower limit: Marginal Relief
CTM03930: No associated companies: Accounting period less than 12 months
CTM03935: Company with associated companies
CTM03940: Associated company definition: Introduction
CTM03941: Associated company definition: Control by the same person or persons
CTM03942: Associated company definition: Association by holding fixed rate preference shares
CTM03943: Associated company definition: Association through a loan creditor
CTM03944: Associated company definition: Association through a trustee
CTM03945: Associated company definition: Exclusions
CTM03948: Associated company definition: Attribution to persons of rights and powers of their partners
CTM03949: Attribution to persons of rights and powers of their partners: commercial interdependence with companies controlled by associates
CTM03950: Substantial commercial interdependence: financial, economic and organisational links
CTM03951: Close investment holding companies
CTM03955: Accounting period straddling financial year - differing relevant amounts or limits
CTM03956: Change in number of associated companies but no change in rates or thresholds
CTM03957: Change in number of associated companies and a change in the CT rates
CTM03958: Change in number of associated companies and a change in the marginal relief thresholds
Close section
CTM04000: Trading losses - general
CTM04005: Computation of loss
CTM04020: Entitlement to relief
CTM04050: Reliefs available
CTM04100: Relief for losses carried forward - summary
CTM04105: Losses incurred before 1 April 2017
CTM04110: Losses incurred from 1 April 2017: amount available for carry-forward
CTM04115: Losses incurred from 1 April 2017: carry-forward against total profits
CTM04120: Losses incurred from 1 April 2017: carry-forward against profits of the same trade
CTM04125: Losses incurred from 1 April 2017: subsequent periods
CTM04130: Losses incurred from 1 April 2017: terminal losses
CTM04135: Claims
CTM04150: Relief for losses carried forward - finality of figures
CTM04200: Relief for losses carried forward - companies going into partnership
CTM04250: Relief for losses carried forward - inclusion of interest & dividends in trading income
CTM04400: Restriction for Government investment written off
Close section
CTM04500: Trading losses - relief against total profits
CTM04505: Introduction
CTM04507: Preceding accounting periods: contents
CTM04570: Evidence of loss
CTM04580: Claims
CTM04590: Late claims
CTM04600: Restriction of relief for uncommercial trading
CTM04610: Restriction of relief for uncommercial trading - meaning of ‘profit’
CTM04620: Restriction of relief for uncommercial trading - meaning of ‘larger undertaking’
CTM04630: No relief for losses of a company that carries on a trade outside the UK
CTM04710: Restrictions for farming companies
CTM04730: Restrictions for farming companies - commencement and cessation
Close section
CTM04800: CT loss reform: contents
CTM04810: Introduction
CTM04820: Scope
CTM04830: Restriction
CTM04835: Administrative requirements for the deductions allowance
CTM04836: Template for the group allowance allocation statement
CTM04840: Relaxation
CTM04850: Group relief for carried-forward losses
CTM04860: Claims
CTM04870: Anti-avoidance
CTM04880: Commencement and apportionment
CTM04890: Commencement: companies affected by the corporate interest restriction
CTM04900: Commencement: note concerning examples
CTM04910: Commencement: example 1: company makes overall loss in the AP straddling 1 April 2017
CTM04920: Commencement: example 2: alternative treatment of NTLRDs arising in the AP straddling 1 April 2017
CTM04930: Commencement: example 3: company makes overall profit in the AP straddling 1 April 2017: no carried-forward losses relieved in the period
CTM04940: Commencement: example 4: company makes overall profit in the AP straddling 1 April 2017: carried-forward losses relieved in the period
CTM04950: Commencement: example 5: company makes overall profit in the AP straddling 1 April 2017: carried-forward losses relieved in the period and losses carried-forward from the period
CTM04960: Commencement: example 6: company makes overall profit in the AP straddling 1 April 2017: carried-forward losses relieved in the period and group relief
CTM04970: Commencement: example 7: company makes overall profit due to the effects of the corporate interest restriction
Close section
CTM05000: Restriction on relief for carried-forward losses: contents
CTM05010: Introduction
CTM05020: Restricted losses
CTM05030: Overview of calculation
CTM05040: Modified total profits
CTM05050: Trading, non-trading profits and chargeable gains
CTM05060: In-year reliefs
CTM05070: Qualifying profits
CTM05080: Relevant profits
CTM05090: Relevant maxima
CTM05100: Interaction with other reliefs
CTM05110: Company has more than one trade
CTM05120: Deductions allowance general
CTM05130: Deductions allowance for a company not in a group
CTM05140: Deductions allowance for a company in a group for a whole accounting period
CTM05150: Deductions allowance for a company in a group for part of an accounting period
CTM05160: Deductions allowance definition of a group
CTM05170: Deductions allowance procedure for groups
CTM05180: Deductions allowance nominated companies
CTM05190: Group deductions allowance
CTM05200: Group allowance allocation statement
CTM05210: Maximum deductions allowance that can be allocated to a company
CTM05220: Excessive group deductions allowance allocated
CTM05230: Deductions allowance and the company tax return
CTM05240: Example 1: company using only streamed carried-forward losses
CTM05250: Example 2: company using streamed and relevant deductions
CTM05260: Examples 3 and 4: companies using relevant deductions only
CTM05270: Example 5: companies with restricted carried-forward capital losses
CTM05280: Increase of deductions allowance in connection with onerous or impaired leases
Close section
CTM06000: Company reconstructions
CTM06005: Without change in ownership - general
CTM06010: Common ownership
CTM06020: Tests of ownership
CTM06030: Beneficial ownership
CTM06060: Transfers of trade
CTM06065: Transfers of trade: without change in ownership - terminal losses
CTM06070: Without change in ownership - later events
CTM06110: Without change in ownership - effects
CTM06120: Loss streaming
CTM06130: Apportionment of profits and losses
CTM06200: Arrangements for transfer of leasing contracts
CTM06210: Avoidance
CTM06250: Relevant liabilities restriction - introduction
CTM06260: Relevant liabilities restriction - particular aspects
CTM06270: Relevant liabilities restriction - details
CTM06280: Relevant liabilities restriction - examples
CTM06290: EU Tax Merger Directive
Close section
CTM06300: Loss buying
CTM06305: Introduction
CTM06310: Identifying cases
CTM06320: Advising taxpayers
CTM06340: Change in ownership
CTM06350: Groups of companies
CTM06355: change in ultimate parent
CTM06370: Major change in nature or conduct of a trade
CTM06380: SP10/91
CTM06390: Trading activities becoming small or negligible
CTM06400: Company reconstructions
CTM06420: Accounting period in which change of ownership occurs
CTM06430: Capital allowances
CTM06450: Profit-buying
Close section
CTM06500: Company purchase schemes
CTM06505: Introduction and signposts
CTM06510: Scope
CTM06520: Aspects
CTM06530: Intent
CTM06540: ‘Reasonable to infer’ test
CTM06550: Information powers
CTM06560: Submissions
Close section
CTM06600: Change of ownership: Shell Companies
CTM06610: Introduction
CTM06620: Non-Trading Amounts Restricted
CTM06630: Apportionment of Non-Trading Amounts
Close section
CTM06700: Loss buying: accounting periods from 1 April 2017
CTM06705: Introduction
CTM06710: Modification of pre-existing provisions
CTM06715: Provisions introduced in F(No 2)A 2017
CTM06720: Change in company ownership
CTM06725: Change in ownership occurs mid-accounting period
CTM06730: Five year period ends mid-accounting period
CTM06735: Related companies and co-transferred companies
CTM06740: Major change in the business of a transferred company
CTM06780: Assets transferred between companies
CTM06810: Restriction of group relief for carried-forward losses
CTM06850: Transfer of trade
Close section
CTM07000: Transfer of deductions
CTM07010: Introduction
CTM07020: Qualifying changes
CTM07030: Highly Likely Disallowed Deductions
CTM07040: Motive Test
CTM07050: loss Shifting: disallowance of deductible amounts for group relief, group relief for carried-forward losses or sideways loss relief
CTM07060: Transfer of Profits into Newly Acquired Company with Available Deductions
Close section
CTM07500: Loss refresh / tax avoidance involving carried forward losses
CTM07505: Overview
CTM07510: Loss refreshing
CTM07515: Relevant carried-forward losses
CTM07520: Conditions for the rule to apply
CTM07525: Identifying the tax arrangements
CTM07530: Deductible amounts
CTM07535: Tax value and non-tax value
CTM07540: Effect where the rules apply
CTM07545: Commencement and apportionment
CTM07550: Example arrangements
Close section
CTM07900: Targeted anti-avoidance rule: contents
CTM07905: Targeted anti-avoidance rule: summary
CTM07910: Targeted anti-avoidance rule: key terms
CTM07915: Targeted anti-avoidance rule: commencement
Close section
CTM08000: Management expenses
CTM08005: Introduction
CTM08020: Investment company - status
CTM08030: Investment company - principal part of income
CTM08040: Investment company - with investment business
CTM08050: Investment company - business of making investments - case law
CTM08060: Company status - parent or holding companies
CTM08070: Company status - cessation of trade
CTM08080: Company status - liquidation
CTM08090: Company status - housing associations
CTM08100: Company status - investment funds
CTM08110: Company status - Development Corporations
CTM08150: General
CTM08160: General - case law
CTM08170: Wholly and exclusively
CTM08180: Groups
CTM08190: Changing investments - general test
CTM08200: Take-over bid defence costs
CTM08210: Avoidance and Unallowable Purpose - General
CTM08215: Unallowable Purpose
CTM08220: Unallowable purpose - business or commercial purpose test
CTM08225: Unallowable Purpose - activities within the charge to tax
CTM08230: Targeted Anti_Avoidance Provision - introduction and commencement
CTM08232: Targeted Anti-Avoidance Regulations (TAAR) - General
CTM08234: TAAR - Purpose
CTM08235: TAAR - examples of arrangements caught
CTM08236: TAAR - arrangements
CTM08238: TAAR - tax advantage
CTM08239: TAAR - outlying provisions
CTM08240: Capital v revenue
CTM08250: Capital exclusion - periods starting on or after 1 April 2004
CTM08260: Capital exclusion - acquisitions and disposals - periods starting on or after 1 April 2004
CTM08300: Raising finance
CTM08310: Short interest
CTM08320: Insurance premiums
CTM08330: Directors' remuneration
CTM08340: Pension contributions: contents
CTM08360: Employees' relocation expenses
CTM08370: Employees seconded to charities
CTM08380: Charity agencies payroll giving scheme
CTM08390: Employee share schemes costs
CTM08400: Redundancy payments
CTM08410: Administrative costs
CTM08420: Valuations
CTM08430: Statutory provisions
CTM08440: property business
CTM08450: Capital allowances on machinery and plant
CTM08455: Capital allowances on structures and buildings
CTM08460: Restrictive covenants
CTM08470: Timing of deduction of emoluments
CTM08550: Meaning of ‘disbursed’
CTM08560: Timing of relief - periods starting on or after 1 April 2004
CTM08570: Reversals
CTM08580: Method of relief and computation
CTM08600: Appeals
CTM08610: Order of set-off
CTM08620: Carry forward and group relief of excess expenses
Close section
CTM08700: Change of ownership - companies with investment business
CTM08710: Introduction
CTM08720: Conditions
CTM08750: Significant increase in capital
CTM08770: During an accounting period (S677)
CTM08780: Excess over profits
CTM08800: Apportionment of ‘amounts in issue’
CTM08850: Restriction for accounting periods ending on or after 1 April 1996 (S677)
CTM08880: Chargeable gain on disposal of asset acquired from another member of the group
CTM08900: During an accounting period (S692)
CTM08910: Apportionment between notional accounting periods
CTM08930: Restriction for accounting periods ending on or after 1 April 1996 (S692)
Close section
CTM09000: Charitable donations relief
CTM09005: Introduction
CTM09010: Definition of qualifying charitable donations
CTM09060: Gift Aid
Close section
CTM09500: Relief for expenditure on grassroots sport - CTA10/PART6A
CTM09501: Introduction and overview
CTM09505: Process and procedure
CTM09510: Background
CTM09515: Qualifying expenditure
CTM09520: Eligibility for deduction - qualifying sport body
CTM09525: Operation of CTA10/PART6A
CTM14000: Non-corporate distribution rate
Close section
CTM15000: Distributions
Close section
CTM15100: General
CTM15120: Introduction
CTM15130: Explanation of terms
CTM15140: New consideration
CTM15150: Tax consequences
CTM15200: Dividends and tax law
CTM15205: Dividends, distributions and company law
CTM15210: Preference share lending
CTM15250: Transfer of assets and liabilities by/to members
CTM15260: Issue of shares at par
CTM15270: Dividend waivers and application of the settlements legislation
CTM15280: Transfers not at market value - other tax implications
CTM15290: Transfers not at market value - to member who is an employee/director
CTM15295: Inadvertent distribution
CTM15300: Disapplication of the distribution provisions
CTM15310: Transfers between companies within the charge to CT
CTM15330: Valuations
CTM15340: LEAs, LECs & TECs
CTM15350: Out of assets in respect of shares
CTM15400: Repayment of share capital - bonus issues
CTM15410: Repayment of share capital - bonus issues - exceptions
CTM15420: Repayment of share capital - bonus issues - after repayment
CTM15430: Repayment of preference shares
CTM15440: Repayment of share capital: share capital/share premium reduction
CTM15450: Bonus issues of securities or redeemable shares
CTM15500: Interest or other value in respect of securities - introduction
CTM15501: Interest or other value in respect of securities - principal secured
CTM15502: Interest or other value in respect of securities - reasonable commercial return
CTM15503: Interest or other value in respect of securities - which reflects return on issuer's own shares or those of associated companies
CTM15504: Interest or other value in respect of securities - hedging arrangements
CTM15505: Interest or other value in respect of securities - reasonable commercial return - examples
CTM15515: Securities within CTA 2010, s 1000 (1) E and F
CTM15520: Securities within CTA 2010, s 1000 (1) F
CTM15525: Ratchet loans
CTM15530: Exclusion of certain interest or other amounts
CTM15540: Unincorporated associations
CTM15550: Companies not carrying on a business
CTM15560: Reciprocal arrangements
CTM15570: Notification of likely higher rate liability
Close section
CTM15900: Non-qualifying distributions
CTM15910: Return of non-qualifying distributions
CTM15920: Form CT2
CTM15930: Action on receipt of return
CTM15940: Nominees
CTM15950: Receipt of distribution
CTM15960: Transactions not returned
CTM15970: Information required
Close section
CTM16000: Impact on Corporation Tax
Close section
Distributions received and franked investment income
CTM16050: Introduction
CTM16100: Receipt by UK resident company
CTM16120: Franked investment income - general
Close section
Franked investment income under the ACT system (abolished from 6 April 1999)
CTM16130: Franked investment income - use of
CTM16200: Franked investment income - surplus - claims under ICTA 1988, s 242
CTM16210: Franked investment income - surplus - claims under ICTA 1988, s 242 - computation
CTM16215: Franked investment income - surplus - claims under ICTA 1988, s 242 - change in rate of tax credit
CTM16220: Franked investment income - surplus - claims under ICTA 1988, s 242 - purposes of claim
CTM16230: Franked investment income - surplus - claims under ICTA 1988, s 242 - relief for less than a complete accounting period
CTM16240: Franked investment income - surplus - claims under ICTA 1988, s 242 - order of set-off
CTM16250: Effect of later payments of ACT - restoration of losses
Close section
CTM17000: Stock dividends
CTM17005: Introduction
CTM17010: Definitions
CTM17030: Transitional provisions
CTM17040: Returns
Close section
CTM17200: Demergers
CTM17250: Introduction
CTM17260: Clearance procedure and returns
CTM17270: Action required in offices
CTM17280: Methods of demerging
CTM17290: Chargeable payments
CTM17300: Reference to Clearance Team
CTM17310: Liquidation reconstruction
CTM17320: Legal costs
Close section
CTM17500: Purchase of own shares
CTM17505: Introduction
CTM17507: Quoted and unquoted companies
CTM17510: Application of the distributions legislation
CTM17520: Shares Issued at a premium
CTM17530: Previous bonus issue
CTM17540: Later bonus issue
CTM17550: Repeat bonus issues
CTM17560: Quoted shares
CTM17570: Special treatment for unquoted companies
CTM17580: Return of payment
CTM17590: Scheme or arrangement
CTM17600: Legal costs
CTM17630: From a dealer
CTM17640: Treatment of purchase price in hands of dealer
CTM17650: Redemption of certain preference shares held by a dealer
Close section
CTM18000: Shadow ACT
CTM18200: Set-off of ACT - accounting periods ending on or before 5 April 1999
CTM18210: Set-off of ACT - accounting periods beginning before and ending after 5 April 1999
CTM18220: Set-off of ACT - accounting periods beginning on or after 6 April 1999
CTM18230: Unrelieved surplus ACT
CTM18250: Outline of the scheme
CTM18260: Companies to which the regulations apply
CTM18300: Definition of a group
CTM18320: Definition of parent and subsidiary companies
CTM18350: Definition of a group - additional tests for 51% subsidiaries
CTM18360: Definition of a group - additional tests for parent companies
CTM18370: Definition of a group - arrangements
CTM18400: Accounting periods to which the Regulations apply - company not a member of a group - immediate opt out
CTM18420: Accounting periods to which the Regulations apply - company not a member of a group - no immediate opt out
CTM18430: Accounting periods to which the Regulations apply - company not a member of a group - unrelieved surplus ACT available for set off exhausted
CTM18450: Accounting periods to which the Regulations apply - company not a member of a group - later opt out
CTM18470: Accounting periods to which the Regulations apply - group members
CTM18480: Accounting periods to which the Regulations apply - group members - immediate opt out
CTM18500: Accounting periods to which the Regulations apply - group members - unrelieved surplus ACT available for set off exhausted
CTM18510: Accounting periods to which the Regulations apply - group members - later opt out
CTM18550: Computation of - introduction
CTM18570: Computation of - subsidiary with election under Regulation 11 (3)
CTM18580: Computation of - surplus franked investment income
CTM18590: Computation of - distributions outside an accounting period
CTM18600: Computation of - company ceasing to be a member of a group
CTM18650: Utilisation of - overview
CTM18670: Utilisation of - Double Taxation Relief
CTM18680: Utilisation of - carry back
CTM18700: Utilisation of - allocation of surplus within groups
CTM18710: Utilisation of - companies leaving and joining a group
CTM18720: Unrelieved surplus - set-off
CTM18730: Unrelieved surplus - restriction on set-off of arising as the result of a surrender
CTM18750: Unrelieved surplus - ACT buying
CTM18760: Unrelieved surplus - change of ownership of company
CTM18770: Unrelieved surplus - asset transferred after change in ownership of company
CTM18800: Unrelieved surplus - recovery of ACT wrongly set off
CTM18810: Unrelieved surplus - displacement of
CTM18850: Controlled foreign companies liabilities
Close section
CTM20000: Advance Corporation Tax (ACT)
Close section
CTM20050: General
CTM20055: Distributions
CTM20060: Franked payments
CTM20065: Rate of ACT
CTM20070: Qualifying and non-qualifying distributions
CTM20075: Bonus issue of securities or redeemable shares
CTM20080: Bonus issue of shares - repayment of share capital
CTM20085: Repayment of shares and securities
CTM20090: Ultra vires dividends
CTM20095: Notes on company law aspects of dividends
Close section
CTM20100: Set off against CT on profit
CTM20105: Introduction
CTM20110: Double taxation relief
CTM20120: Amount available
CTM20140: Definitions
CTM20150: Maximum
CTM20160: Surplus ACT
CTM20170: Surplus ACT carry back
CTM20180: When a claim could be made
CTM20190: Form of claim
CTM20200: Withdrawal or variation of claims
CTM20210: Repayment from carry-back of surplus
CTM20220: Interest advantage pre pay and file
CTM20230: Not creating surplus ACT
CTM20240: Time limit
CTM20250: Carry-forward surplus ACT
CTM20260: Excessive set-off
CTM20300: Capacity buying - introduction
CTM20310: Capacity buying - conditions
CTM20320: Capacity buying - meaning of ‘major change’
CTM20330: Capacity buying - effect of applying rules
Close section
CTM20500: Tax credit & FA93
CTM20505: Background
CTM20510: Summary of main changes
CTM20515: Reason for the changes
CTM20520: Effects of main changes
CTM20525: Rate at which ACT is payable
CTM20530: Rate of tax credit
CTM20535: Claims under ICTA 1988, s 242 & ICTA 1988, s 243
CTM20540: Franked investment income - as upper limit
CTM20545: Franked investment income - used to frank payments
CTM20550: Franked investment income - small companies relief and mutual concerns
CTM20555: Stock dividends - IT treated as paid
CTM20560: Loan released or written off
CTM20565: Non-qualifying distributions etc
CTM20570: FID
Close section
CTM21000: FID - general
CTM21005: Background
CTM21010: Overview
CTM21100: Election - effect of
CTM21110: Election - conditions
CTM21120: Election - ICTA 1988, s 247 (1) election already in place
CTM21130: Election - procedure for
CTM21150: Election - specific rules
CTM21160: Election - individuals
CTM21170: Election - personal representatives
CTM21180: Election - trustees
CTM21200: Election - dividend vouchers
CTM21210: Election - information powers
CTM21220: Excess FID
CTM21230: Authorised unit trusts
CTM21240: Repayment interest
CTM21250: Accounting procedures
CTM21260: Anti-streaming provisions
CTM21270: How legislation operated in practice - summary
CTM21280: How legislation operated in practice - examples
Close section
CTM21300: FID - foreign profits
CTM21305: Definitions and outline of scheme
CTM21310: Matching FID with distributable foreign profits (DFP) - outline
CTM21320: Matching FID with DFP - of same company
CTM21330: Matching FID with DFP - of a subsidiary
CTM21340: Matching FID with DFP - meaning of 51% subsidiary
Close section
CTM21400: FID - repayment or set off of ACT
CTM21405: Outline
CTM21410: ACT already dealt with
CTM21420: Notional foreign source
CTM21430: Qualifying FID
CTM21440: Matched foreign source profits
CTM21450: Procedure
CTM21452: Provisional repayment
CTM21455: Evidence for repayment
CTM21460: Additional claims
CTM21480: Revision of profits
Close section
CTM21500: FID - international headquarters companies
CTM21505: Introduction
CTM21510: Conditions
CTM21520: Whether company is an IHC
CTM21530: Foreign held
CTM21535: Ownership of share capital
CTM21540: Company found not to be an IHC
CTM21550: Further reckoning comparison
CTM21560: Further reckoning following additional matching
Close section
CTM22000: Collection
CTM22010: Introduction
CTM22050: Return periods
CTM22060: Contents of returns
CTM22070: Date payable
CTM22080: Franked investment income received in a later return period
CTM22085: FID received in later return period
CTM22090: Claims
CTM22100: Franked payments which are not money payments
CTM22110: Payments of an uncertain nature
CTM22150: Items included in error
CTM22160: Franked payments not made in an accounting period
CTM22170: Franked payments or FID paid not returned
CTM22180: ACT not paid
CTM22190: Composite assessments
CTM22200: Time limits
CTM22210: Appeals
CTM22220: Due and payable date - assessments
CTM22250: Changes in rate of ACT
CTM22260: Amount of set-off - different rates
CTM22270: Calculations
CTM22280: Effect of the provisions
CTM22350: International headquarters companies - general
CTM22360: International headquarters companies - assessments
Close section
CTM34000: Residence
Close section
CTM34050: Inward company migration
CTM34060: Establishing residence
CTM34070: Deemed commencement - specific points
CTM34080: Capital gains
Close section
CTM34100: Outward company or permanent establishment migration
CTM34110: Before 15 March 1988
CTM34120: From 15 March 1988
CTM34130: Liabilities arising: introduction
CTM34131: Liabilities arising: deferral of exit charges: background
CTM34132: Liabilities arising: deferral of exit charges: eligible companies and conditions
CTM34133: Liabilities arising: deferral of exit charges: exit charge payment plan: general
CTM34134: Liabilities arising: deferral of exit charges: exit charge payment plan: instalment method
CTM34135: Liabilities arising: deferral of exit charges: exit charge payment plan: realisation method: outline
CTM34136: Liabilities arising: deferral of exit charges: exit charge payment plan: realisation method: tax deferral and annual reports
CTM34137: Liabilities arising: deferral of exit charges: exit charge payment plan: action in HMRC offices: technical issues
CTM34138: Liabilities arising: deferral of exit charges: exit charge payment plan: action in HMRC offices: other issues
CTM34139: Liabilities arising: deferral of exit charges: exit charge payment plan: action in HMRC offices: on and following acceptance of claim
CTM34140: Ceasing residence for double taxation agreement purposes
CTM34160: Notice and arrangements
CTM34170: HMRC office action
CTM34180: Penalties for non-compliance
CTM34190: Recovery of tax from other persons
CTM34195: Guidance notes for migrating companies
Close section
CTM34200: Non-resident companies
CTM34210: Liability to CT
CTM34220: Liability to IT
CTM34230: Differences in treatment compared with resident companies
CTM34240: ‘Charges paid’ - relief for annual payments and patent royalties
CTM34250: ‘Charges received’: income from which income tax has been deducted
CTM34260: Securities in respect of which distributions may arise
CTM34270: Distributions received
CTM34300: Avoidance transactions
Close section
CTM34500: Dual resident companies
CTM34505: Introduction
CTM34510: Legislation
CTM34530: Definition
CTM34560: Definition - investing company
CTM34590: Advice from Head Office
CTM34600: Anti-avoidance - limitation of group relief
CTM34610: Anti-avoidance - limitation of loss relief
CTM34620: Anti-avoidance - limitation of other reliefs
CTM34700: Accounting periods straddling 1 April 1987
CTM34710: Apportionment of losses: accounting periods straddling 1 April 1987
CTM34720: Anti-forestalling provisions
CTM34730: Early payment of charges on income
CTM34740: Early payment of interest
CTM34750: Board's direction
CTM34760: Group reorganisations
CTM34770: Reports to Business International
Close section
CTM35000: Income Tax
CTM35050: Accounting for tax deducted from yearly interest etc
Close section
CTM35100: Collection of tax on annual payments
CTM35105: Introduction
CTM35110: Return periods
CTM35115: Contents of returns
CTM35120: Date tax payable
CTM35125: Set off of tax suffered by deduction
CTM35130: Amended return where company becomes aware of an error
CTM35135: Items included in error
CTM35140: Payment made otherwise than in an accounting period
CTM35145: Relevant payments not returned
CTM35150: Unpaid tax
CTM35155: Composite assessments
CTM35160: Time limits
CTM35165: Appeals
CTM35170: Due and payable date on assessments
Close section
CTM35200: Deduction of tax
CTM35205: Introduction
CTM35210: Payments made before 1 April 2001
CTM35215: Payments made on or after 1 April 2001
CTM35218: Eurobonds and deduction of tax
CTM35220: Income received net
CTM35250: Conditions for a set-off claim under ITA 2007, s 952 (formerly ICTA 1988, Sch 16 para 5)
CTM35270: Royalties paid overseas
Close section
CTM36000: Particular topics
Close section
CTM36100: Company winding up etc
CTM36105: Introduction
CTM36110: Unincorporated associations
CTM36115: Profits chargeable
CTM36120: Accounting periods
CTM36125: Beneficial ownership of shares
CTM36130: Distributions
CTM36135: Responsibility of Officer
CTM36140: Procedure
CTM36145: Review office
CTM36150: Investment of surplus funds by the Department of for Business, Innovation and Skills
CTM36155: Transfer of business
CTM36160: Assessments under appeal or enquiry
CTM36180: Receiver appointed on behalf of debenture holders
CTM36185: Administrative receivership cases
CTM36190: Schemes of arrangement
Close section
CTM36200: Company dissolution
CTM36205: Distributions in anticipation of dissolution: introduction
CTM36210: Loans to participators
CTM36220: Distributions treated as being made on formal winding up
CTM36230: ESCC16: already dissolved
CTM36240: Company not dissolved
Close section
CTM36300: Company winding up TAAR
CTM36305: Targeted anti-avoidance rule (TAAR)
CTM36310: Condition A
CTM36315: Condition B
CTM36320: Condition C: introduction
CTM36325: Condition C: ‘similar to’
CTM36330: Condition C: ‘involved with’
CTM36335: Condition C: ‘connected with
CTM36340: Condition D
CTM36345: Exclusions
CTM36350: Requests for clearance
Close section
CTM36500: Companies in partnership
CTM36505: Introduction
CTM36510: Computation of profits and losses
CTM36520: Different classes of partner
CTM36530: Loan relationships etc
CTM36540: Interest paid etc
CTM36550: Limited and limited liability partnerships
CTM36560: Investment partnerships
CTM36570: Investment partnerships - procedures for
CTM36580: British Venture Capital Association statement and guidelines
CTM36590: Transfer of relief between companies and partnerships
Close section
CTM36600: Rent factoring
CTM36610: Repeal of rent factoring legislation from 6 June 2006
Close section
CTM36700: Dividend stripping
CTM36705: Repeal of ICT88/S736
Close section
CTM36800: Transactions in securities
CTM36805: Introduction
CTM36806: Persons affected
CTM36810: Definitions
CTM36815: Income tax advantage
CTM36820: ‘Circumstances’ and relevant consideration
CTM36822: Condition A
CTM36823: Condition B
CTM36825: Personal representatives
CTM36830: Excluded circumstance
CTM36835: Corporation Tax advantage
CTM36840: Clearances
CTM36841: Application
CTM36845: Response to a clearance application
CTM36850: Examples of common circumstances where clearance will be given: examples
CTM36851: Examples
CTM36860: Clearance: internal communications
CTM36865: Counteraction: introduction
CTM36875: Identification of cases
CTM36880: Submissions to Clearance & Counteraction Team
CTM36900: Transactions between dealing and non-dealing associated companies
Close section
CTM40000: Particular bodies
Close section
CTM40050: Charities
CTM40055: General
CTM40060: Trading
CTM40065: ‘Profit shedding’ by Gift Aid
Close section
CTM40100: Clubs
CTM40105: Introduction
CTM40110: Incorporated under Industrial & Provident Societies Acts
CTM40115: Incorporated as companies
CTM40120: Incorporated as companies - dividends not paid
CTM40125: Incorporated as companies - dividends paid
CTM40130: Associate members, visitors' fees, etc
CTM40135: Machine commissions
CTM40140: Community Associations
CTM40141: Sports clubs
CTM40145: Community Interest Companies
Close section
CTM40150: Credit unions
CTM40155: Introduction
CTM40160: Taxation of union
CTM40162: Returns required
CTM40165: Taxation of members
CTM40200: Farming
Close section
CTM40300: Friendly societies
CTM40305: Introduction
CTM40310: Meaning of friendly society
CTM40315: General scheme of taxation
CTM40320: Business categories
CTM40325: Exemption for life or endowment business
CTM40330: Pension business
CTM40335: Exemption for ‘other business’
CTM40340: Repayment claims
CTM40345: Partnership societies
Close section
CTM40350: Health service bodies
CTM40355: Introduction
CTM40360: IT deducted from payments received
CTM40365: Repayment claims
Close section
CTM40400: Housing associations
CTM40405: Introduction
CTM40410: Summary of tax treatment
CTM40415: Co-operatives - background
CTM40420: Co-operatives - nature of relief and claim
CTM40425: Co-operatives - approval
CTM40430: Co-operatives - interest paid
CTM40435: Co-operatives - unlet properties
CTM40440: Co-operatives - disqualifying letting
CTM40445: Co-operatives - death of a member
CTM40450: Housing Act tax relief grants
CTM40460: Charity aspects
CTM40465: Management co-operatives
CTM40470: Self-build societies
Close section
CTM40500: Registered societies
CTM40505: General
CTM40507: Background and types of society
CTM40510: Claims for exemption
CTM40513: Payments not distributions
CTM40515: Carrying on trade - dividends etc (‘divi’)
CTM40520: Share and loan interest paid: the society
CTM40525: Returns of gross payments
CTM40530: Payment of share and loan interest and other payments: treatment of recipient
CTM40535: Accounting periods of retail co-operatives
CTM40540: Relief for losses carried forward
CTM40545: Assets transferred to another society
CTM40550: Conversion to a Companies Act company and vice versa
CTM40555: Financial compensation
CTM40560: Carrying on trade - collective assurances
CTM40565: Carrying on trade - allowable deductions
CTM40570: Share and loan interest paid by non-trading societies
CTM40575: Allotment and garden societies
CTM40580: Agricultural and fishing co-operatives treated as registered societies
CTM40600: Insurance companies
CTM40650: Investment clubs
CTM40700: Investment trusts
CTM40750: Lloyd's underwriting agents
Close section
CTM40800: Loan & money societies
CTM40805: General
CTM40810: Thrift funds
Close section
CTM40850: Local authorities
CTM40855: Introduction
CTM40860: Definition
CTM40865: Associations or groups of authorities
CTM40870: Receipt or payment of gross interest
CTM40880: Income tax deducted from payments received
CTM40890: Securities expressed in foreign currency
CTM40895: LEAs, schools and colleges
CTM40900: Marketing boards
Close section
CTM40950: Mutual concerns
CTM40955: Surplus from mutual trading not liable
CTM40960: Legal framework
CTM40965: Non-mutual transactions
CTM40970: Mutuality
CTM40975: Distributions
CTM40980: Co-operatives
CTM40985: Agricultural co-operatives
CTM41000: Oil and gas companies
CTM41020: Public bodies
CTM41050: Retirement benefit schemes
CTM41100: Scientific research associations
CTM41110: Sports testimonials or benefit committees
CTM41150: Trade organisations
Close section
CTM41200: Trade associations
CTM41205: Within the charge to Corporation Tax
CTM41210: Special arrangement
CTM41215: Arrangement procedure
CTM41220: Payments to members
Close section
CTM41250: Trade unions and eligible employers' associations
CTM41255: Introduction
CTM41260: Provident benefits - extent of relief
CTM41265: Provident benefits - nature of payment
CTM41270: Provident benefits - new claims
CTM41275: Provident benefits - method of allowing relief
CTM41290: Provident benefits - employers associations
Close section
CTM41300: Unincorporated associations
CTM41305: Definition
CTM41310: Examples
CTM41315: Is it a partnership?
CTM41320: Trustees
CTM41325: Part of a wider undertaking?
CTM41330: Transfers of trade
CTM41335: Cessation
Close section
CTM41350: Pharmaceutical cases
CTM41355: Background
CTM41360: Definition
CTM41370: Transfer arrangements
CTM41375: Pharmaceutical specialist offices within Mid-sized Business
CTM41380: Interaction with Small Company Enterprise Centres (SCECs)
CTM41385: Contact point
CTM48000: Authorised investment funds (AIFs)
Close section
CTM48800: Property authorised investment funds (Property AIFs)
Close section
CTM48900: Tax elected funds (TEFs)
CTM48910: Introduction and conditions of membership for the regime: contents
CTM48920: Application process and effects of entry to the TEF regime: contents
CTM48930: Tax treatment and distributions made by TEFs: contents
CTM48940: Tax treatment of distributions in the hands of participants: contents
CTM48950: Provisions for providing tax information to participants: contents
CTM48960: Breaches of conditions: contents
CTM48970: Leaving the TEF regime: contents
Close section
CTM49000: Building societies
CTM49100: General
Close section
CTM49300: Deduction of Income Tax
CTM49360: Main features
CTM49365: Return periods
CTM49370: Deduction of income tax from interest on marketable securities
CTM49380: Deduction of income tax from interest on marketable securities - return periods
CTM49390: Deduction of income tax from annuities or other annual payments - return periods
Close section
CTM49400: Application of Corporation Tax
CTM49405: Scope
CTM49415: How profits arise
CTM49420: Loan relationships
CTM49426: Other investments
CTM49428: Interest received taxed
CTM49430: Income from property
CTM49440: Rents payable
CTM49450: Profits on mortgaged properties sold
CTM49475: Terminal bonus payments
CTM49480: Permanent interest-bearing shares
CTM49485: Permanent interest-bearing shares - incidental costs
CTM49500: Subscriptions
CTM49510: Impairment losses
CTM49520: Capital allowances and charges
CTM49560: Losses
CTM49570: Capital gains
CTM49620: Mergers
CTM49630: Mergers - bonus payments
CTM49640: Conversion into plc
CTM50000: Loan relationships
Close section
CTM60000: Close companies
Close section
CTM60050: General
CTM60055: Introduction
CTM60060: Broad definition
CTM60070: Special provisions
Close section
CTM60100: Tests
CTM60102: Introduction
CTM60105: Specific exceptions
CTM60107: Participator
CTM60110: Participator - extended meaning of
CTM60120: Entitled to acquire or secure
CTM60130: Loan creditor
CTM60140: Rights and powers of certain other persons
CTM60150: Associates
CTM60160: Having a share or interest in
CTM60170: Trustees, executors, etc
CTM60180: Definition of director
CTM60200: Control - of a company
CTM60210: Control - definition
CTM60220: Control - over the company's affairs
CTM60230: Control - right to receive most assets
CTM60240: Control - summary
CTM60250: Control - in multiple
CTM60260: Control - exceptions
CTM60270: Control - by the Crown
CTM60280: Control - overseas governments and local authorities
CTM60290: Control - by another company
CTM60300: Open company loan creditor
CTM60310: 35% or more voting power held by public
CTM60320: Rights in a winding-up
CTM60400: Information regarding share holding
CTM60420: Examples
Close section
CTM60500: Extended meaning of distribution
CTM60510: Introduction
CTM60520: Profits chargeable to CT
CTM60530: Notifying office dealing with participators affairs
CTM60550: Valuation of benefits
CTM60600: Benefits to directors and employees
CTM60610: Groups
CTM60620: Companies acting in concert
CTM60660: Payments to participators
CTM60670: Payments to participators - excessive amounts
CTM60680: IT and ACT
CTM60690: Benefits for exempt or lower tax rate participators
Close section
CTM60700: Close investment holding companies
CTM60705: Introduction
CTM60710: Definition
CTM60720: Purpose
CTM60730: Wholly or mainly
CTM60740: Lettings to connected persons
CTM60750: Qualifying company'
CTM60760: Holding companies
CTM60770: Group service companies
CTM60780: Liquidation
CTM60790: Restriction on payment of tax credit
Close section
CTM61000: Capital payments to settlors
CTM61050: Introduction
CTM61060: Interposition between settlor and trustee
CTM61070: Assessable as income
CTM61080: Loans or repayment of a loan
CTM61090: Temporary loans
CTM61100: Loans paid directly or indirectly
CTM61120: Associated payments
CTM61130: Interaction withICTA 1988, s 419 &ICTA 1988, s 421
CTM61150: Available income
Close section
CTM61500: Close companies: loans to participators and arrangements conferring benefit on participator
CTM61505: General
CTM61510: Charging provisions
CTM61515: Meaning of ‘relevant person’
CTM61520: Partnerships
CTM61525: Loans to trusts
CTM61530: Business of lending money
CTM61535: Extended meaning of loan - debt
CTM61537: Unpaid share capital
CTM61540: Exclusion of certain loans
CTM61545: Material interest
CTM61550: Indirect loans
CTM61555: Indirect loans - total income
CTM61558: liquidations/dissolutions: general
CTM61559: Members Voluntary Liquidations (MVL)
CTM61560: Insolvent liquidations and dissolutions
CTM61561: Company insolvent and loan irrecoverable
CTM61565: Aggregating accounts
CTM61570: TAAR - general
CTM61575: TAAR - tax avoidance arrangements
CTM61580: TAAR - conferring benefit
CTM61585: TAAR - partnerships
CTM61600: Repayment of - general
CTM61602: Repayment of - repayment actually made?
CTM61604: Repayment of - transfers of assets
CTM61605: Repayment of - assignment/novation
CTM61610: Repayment of - date relief is due
CTM61615: Bed and Breakfasting - general
CTM61620: Bed and Breakfasting - before 20 March 2013
CTM61625: Bed and Breakfasting - on or after 20 March 2013
CTM61630: Bed and Breakfasting - 30 day rule
CTM61635: Bed and Breakfasting - arrangements rule
CTM61640: Bed and Breakfasting - repeated repayments/loans
CTM61642: Bed and Breakfasting - exclusions
CTM61645: Bed and Breakfasting - flowchart
CTM61646: Bed and Breakfasting - table
CTM61650: Repayment of - how relief is given
CTM61655: Release or writing-off of loan or advance
CTM61657: Release or writing-off while temporarily non-resident
CTM61660: Release or writing-off of loan or advance - Class 1 NIC
CTM61665: Death of recipient
CTM61670: Termination of a trust
CTM61700: By controlled companies
CTM61710: Companies controlled by a close company
CTM61720: Acquisition of control of company
CTM61730: Two or more close companies
CTM61740: Arrangements not caught
CTM61750: Treating loan as made by another company
CTM61760: Referrals - unusual schemes
CTM61790: Assessments
CTM70000: Exchange differences and financial instruments
Close section
CTM80000: Groups & consortia
Close section
CTM80050: Group income
CTM80055: Avoidance of the distributions legislation
CTM80060: Transfers of assets or liabilities
CTM80070: Election to pay dividends without accounting for ACT
CTM80075: Retrospective ICTA 1988, s 247 (3) notice
CTM80080: Election to pay charges or loan relationship interest without accounting for IT
CTM80085: Elections
CTM80090: Recovery of ACT or IT
Close section
CTM80100: Group relief
CTM80105: Structural outline
CTM80110: What can be transferred between group members?
CTM80115: Meaning of trading loss
CTM80120: Meaning of excess capital allowances
CTM80125: Meaning of deficits on non-trading loan relationships
CTM80130: Meaning of qualifying charitable donations
CTM80135: Meaning of UK property business loss
CTM80140: Meaning of excess management expenses
CTM80141: Meaning of non-trading losses on intangible fixed assets
CTM80142: Special rules that apply to “relevant amounts”
CTM80143: Order of relief for amounts which can be surrendered
CTM80145: Claims for relief
CTM80150: Which companies may claim and surrender group relief?
CTM80151: The group relationship
CTM80152: Group relief and partnerships
CTM80155: Shareholding rule plus the entitlement to profits/assets tests
CTM80160: Applying the entitlement to profits/assets tests
CTM80165: Overview of the arrangements rules
CTM80170: Arrangements, effect 1
CTM80175: Arrangements, effect 2
CTM80180: Arrangements, effect 3
CTM80181: Exclusion of certain arrangements
CTM80185: Enabling arrangements
CTM80190: Direct arrangements
CTM80195: Date of arrangements
CTM80196: Contingent arrangements
CTM80205: HMRC's approach to “arrangements” - SP3/93 and ESC C10
CTM80206: Examples of arrangements
CTM80210: Non coinciding accounting periods or group relationships - overview
CTM80215: Non coinciding accounting periods or group relationships - multiple claims
CTM80220: Non coinciding accounting periods or group relationships - the order which claims are dealt with
CTM80225: Non coinciding accounting periods or group relationships - overlapping period
CTM80230: Non coinciding accounting periods or group relationships - unused part of the surrenderable amounts
CTM80235: Non coinciding accounting periods or group relationships - unrelieved part of claimant company's available total profits
CTM80240: Non coinciding accounting periods or group relationships - amount of any prior surrenders attributable thereto
CTM80245: Non coinciding accounting periods or group relationships - amount of any previous claims attributable thereto
CTM80255: Non coinciding accounting periods or group relationships - example
CTM80260: Non coinciding accounting periods or group relationships - time apportionment is not the only permitted method
CTM80265: Non coinciding accounting periods or group relationships - use of management accounts
CTM80270: Non coinciding accounting periods or group relationships - apportioned amount not to exceed total loss
CTM80300: The international aspect - overview
CTM80305: The international aspect - permanent establishments
CTM80310: UK permanent establishment of non-resident company
CTM80315: UK permanent establishment of non-resident company - tax relief in a foreign jurisdiction
CTM80320: Meaning of non-UK profits
CTM80325: Meaning of non-UK tax
CTM80330: UK permanent establishment of non-resident company - tax relief in a foreign jurisdiction - credit and exemption countries
CTM80332: UK permanent establishment of non-resident company - determining tax relief in a foreign jurisdiction for an EEA resident company
CTM80333: UK permanent establishment of non-resident company - determining amount available for surrender in the UK for an EEA resident company
CTM80335: UK permanent establishment of non-resident company - clawing back group relief for losses relieved in foreign jurisdiction for an EEA resident company
CTM80340: UK permanent establishment of non-resident company - losses exempted by double taxation agreements
CTM80345: UK permanent establishment of non-resident company - amounts which can be surrendered
CTM80350: Overseas permanent establishment of UK resident company
CTM80355: Overseas permanent establishment of UK resident company - meaning of attributable to overseas permanent establishment
CTM80360: Overseas permanent establishment of UK resident company - meaning of tax relief in a foreign jurisdiction
CTM80365: Overseas permanent establishment of UK resident company - foreign ‘tie-breaker’ rules
CTM80370: The international aspect - accounting period straddling 1 April 2000
CTM80400: Available total profits
CTM80405: Exclusion of double allowances
CTM80410: Cases of difficulty
CTM80415: Avoidance
CTM80435: Example - surrender of trading losses
CTM80440: Example - surrender of excess capital allowances
CTM80445: Example - surrender of excess management expenses
CTM80450: Example - surrender of excess qualifying charitable donations
Close section
CTM80500: Consortia - group relief
CTM80502: Introduction
CTM80510: Applications of rules
CTM80515: Claims
CTM80520: Claims - consent to be given
CTM80525: Claims - rules limiting
CTM80530: Meaning of members of the consortium and company owned by a consortium
CTM80535: 90% subsidiary
CTM80540: Amount of relief: claimant is member of the consortium: claims based on consortium condition 1
CTM80545: Amount of relief: claimant is company owned by a consortium: claims based on consortium condition 1
CTM80550: Extension to companies in same group as member of the consortium
CTM80555: Claim by company in same group as member of the consortium: claims based on consortium condition 2
CTM80560: Surrender by company in same group as member of the consortium: claims based on consortium condition 3
CTM80570: Items eligible for relief - potential restriction on surrender of trading losses
CTM80580: Group and consortium claims both possible: surrendering company is both owned by a consortium and a member of a group
CTM80585: Group and consortium claims both possible: claimant company is both owned by a consortium and a member of a group
CTM80587: Control arrangements: claimant is member of the consortium
CTM80588: Control arrangements: claimant is company owned by the consortium
CTM80590: Diagram showing meaning of various terms
CTM80600: Arrangements to transfer the company owned by a consortium to another group or consortium
CTM80605: Arrangements - disqualifying relief
CTM80615: Arrangements - definitions
CTM80620: Enabling arrangements
CTM80625: Direct arrangements
CTM80630: Date of arrangements
CTM80635: Information about arrangements
CTM80640: SP3/93 and ESCC10
CTM80670: Example - consortium relief generally
CTM80675: Example: surrender by member of the consortium and by a member of its group, overlapping periods and company joining link company's group
CTM80680: Example: claim by company owned by a consortium from a company in the same group as a member of the consortium
CTM80685: Example - restriction where group claims possible
CTM80690: Example - restriction where group claims are possible by companies which are not group/consortium companies
CTM80695: Example - restriction where group claims are possible
CTM80696: Example - restriction of surrender of trade losses where company owned by consortium has other profits
Close section
CTM80900: Consortia - group income
CTM80905: Election - to pay dividends without ACT
CTM80910: Election - to pay charges on income or loan relationship interest without accounting for IT
CTM80915: Election - under ICTA 1988, s 247
CTM80920: Election - form of
CTM80925: Multiple elections
CTM80930: Election - two companies only involved
CTM80935: Election - validity
CTM80940: Late elections
CTM80945: Election - ceasing to apply
CTM80950: Election - record of
CTM80955: Recovery of ACT or IT
Close section
CTM81000: Groups - entitlement to profits or assets available for distribution
CTM81005: Introduction
CTM81010: Definitions of terminology
CTM81015: Convertible shares and securities
CTM81020: Business results dependency test
CTM81025: Equity holders - special rule
CTM81030: Equity holders - banks
CTM81035: Equity holders - subsidiary profits available to
CTM81040: Equity holders - subsidiary assets available to
CTM81045: Equity holders - percentage of profits available to
CTM81050: Equity holders - notional winding-up
CTM81055: Returned amounts
CTM81060: Limited rights
CTM81065: Effect of limitation of rights
CTM81070: Varying rights for different accounting periods
CTM81075: Varying rights for different accounting periods - effect
CTM81080: Varying and limited rights - effect
CTM81085: Entitlement different - effect
CTM81090: Option arrangements
CTM81095: Effective rights
CTM81100: Option rights exist
CTM81105: Option, limited & varying rights
CTM81110: Option, limited & varying rights - referable to UK trade of non-resident company
CTM81115: Option arrangements - Board's policy
CTM81120: Examples - background
CTM81121: Example 1 - basic rule
CTM81122: Example 2 - limited rights
CTM81123: Example 3 - varying rights for different accounting periods
CTM81124: Example 4 - option rights
Close section
CTM81200: Groups - surrender of ACT
CTM81205: Introduction
CTM81210: Computation of ACT available
CTM81215: Effect of surrender
CTM81220: Order of set-off
CTM81225: Change of ownership - ACT previously surrendered
CTM81230: Change of ownership - ACT previously held
CTM81235: Interest on unpaid tax pre CT Pay and File (CTPF)
CTM81240: Definition of subsidiary
CTM81245: Arrangements regarding control
CTM81250: Entitlement to profits and assets
CTM81255: Claims
CTM81260: Interaction of ICTA 1988, s 239 (1) & ICTA 1988, s 240
CTM81265: Payment by subsidiary for surrender
CTM81270: Arrangements
CTM81275: Date of arrangements
CTM81280: Information about arrangements
Close section
CTM81500: Groups - group relief - surrendering company not UK resident
CTM81502: Outline
CTM81505: Companies affected
CTM81510: Amount of the loss - overview
CTM81515: Amount of the loss - the equivalence condition
CTM81520: Amount of the loss - the EEA tax loss condition
CTM81525: Amount of the loss - the qualifying loss condition
CTM81530: Amount of the loss - the qualifying loss condition - current & previous periods
CTM81535: Amount of the loss - the qualifying loss condition - future periods
CTM81540: Amount of the loss - the qualifying loss condition - not otherwise given
CTM81545: Amount of the loss - the precedence condition
CTM81550: Amount of the loss - the unallowable loss rule
CTM81555: Amount of the loss - unallowable losses and arrangements
CTM81560: Amount of the loss - UK recomputation
CTM81565: Amount of the loss - UK recomputation - residence
CTM81570: Amount of the loss - UK recomputation - accounting periods
CTM81575: Amount of the loss - UK recomputation - capital allowances
CTM81580: Amount of the loss - UK recomputation - intangible assets
CTM81585: Amount of the loss - UK recomputation - loan relationships & derivative contracts
CTM81590: Amount of the loss - comparison of UK and overseas loss
CTM81591: Amount of the loss - information to be provided by claimant company
CTM81595: Amount of the loss - UK recomputation - life assurance companies
CTM81600: Amount of the loss - claims in respect of overseas losses of non-resident companies - overview
CTM81605: Amount of the loss - claims in respect of overseas losses of non-resident companies - enquiries
CTM81610: Examples - the precedence condition
CTM81620: Example - the qualifying loss condition
CTM81625: Examples - comparison of UK and EEA loss
Close section
CTM82000: Group relief for carried-forward losses
CTM82010: General
CTM82020: Types of loss that may be surrendered
CTM82030: Restrictions
CTM82040: Restrictions for certain types of insurance company
CTM82050: Restrictions on companies with permanent establishments or dual residence
CTM82060: Conditions for a claim
CTM82070: Claims
CTM82080: Group Condition
CTM82090: Overlapping period
CTM82100: Order of relief
CTM82110: General limit of relief
CTM82120: Surrenderable amounts
CTM82130: Prior surrenders
CTM82140: Claimant company's relevant maximum
CTM82150: Amount of prior claims
CTM82160: Order in which claims are dealt with
CTM82170: Payment made for loss
CTM82180: Simplified arrangements
CTM82190: Comprehensive example
Close section
CTM82500: Consortia - group relief for carried-forward losses
CTM82505: General
CTM82510: Conditions for a claim
CTM82515: Restrictions general
CTM82520: Restrictions on claims under conditions 1 or 2
CTM82525: Restrictions on claims under conditions 3 or 4
CTM82530: Surrenderable amounts for loss-making period
CTM82535: Prior surrenders relating to loss-making period
CTM82540: Potential Part 5 group relief
CTM82545: Overlapping period
Close section
CTM90000: Corporation Tax self-assessment (CTSA)
Close section
CTM90100: Introduction
CTM90105: Background
CTM90130: Layout of guidance
CTM90140: Applicable legislation
CTM90150: Differences from ITSA
CTM90180: Glossary of Terms
Close section
CTM90600: Claims & elections
CTM90602: Introduction
CTM90605: Quantification
CTM90610: Time limits
CTM90615: Mistakes
CTM90620: Categories
CTM90625: Affecting only one accounting period
CTM90630: Affecting more than one accounting period
CTM90635: Amended return, outside return
CTM90640: Must be made in a return
CTM90645: Outside normal time limits
CTM90650: Consequential claims-general principles
CTM90655: Another person's liability affected
CTM90660: Reduction in overall liability
CTM90665: Consequential claims and elections - deliberate or careless
CTM90670: Relief from double assessment
Close section
CTM92000: The payment obligation
CTM92005: General
CTM92010: Due dates
CTM92030: Amounts payable/repayable
CTM92090: Repayment before liability finally established
CTM92110: Repayment before liability finally established - open appeal
CTM92150: Repayment of IT
CTM92160: Payment of tax credit
CTM92170: Repayment of CIS25/SC60 tax
CTM92180: Late payment interest
CTM92190: Late payment interest - tax deductible
CTM92200: Interest revision for unremittable overseas income or gains
CTM92240: Carry-back of trading losses or non-trading deficit - late payment interest
CTM92250: Carry-back of trading losses or non-trading deficit - late payment interest - summary of examples
CTM92251: Carry-back of trading losses or non-trading deficit - late payment interest - example 1
CTM92252: Carry-back of trading losses or non-trading deficit - late payment interest - example 2
CTM92253: Carry-back of trading losses or non-trading deficit - late payment interest - example 3
CTM92254: Carry-back of trading losses or non-trading deficit - late payment interest - example 4
CTM92290: Credit interest
CTM92310: Repayment interest
CTM92320: Credit interest and repayment interest are taxable
CTM92360: Carry-back of trading losses or non-trading deficit - repayment interest
CTM92440: Repayment - intra-group surrender - CTA 2010, s 963
CTM92460: Repayment - intra-group surrender - joint notice
CTM92480: Payment for surrendered tax refund
Close section
CTM92500: Quarterly instalments
CTM92505: Legislation
CTM92510: Scope
CTM92520: Large companies
CTM92530: Special cases
CTM92550: Identification of large companies
CTM92560: Due dates - 12 month accounting period
CTM92570: Due dates - 12 months accounting period - examples
CTM92580: Due dates - accounting period less than 12 months
CTM92590: Due dates - accounting period less than 12 months - examples
CTM92600: Amount due at each instalment - formula
CTM92610: Amount due at each instalment - how to calculate ‘n’
CTM92640: Company procedure
CTM92650: Repayment before liability finally established
CTM92660: Debit interest
CTM92670: Credit interest
CTM92680: Quarterly instalment payer' (QIP) signal
CTM92690: SA recorded
CTM92710: Calculating debit and credit interest
CTM92730: Handling interest - examples
CTM92740: Intra-group surrender - legislation
CTM92750: Intra-group surrender excessive instalment payments - procedure
CTM92760: Intra-group surrender excessive instalment payments - examples
CTM92770: Information powers
CTM92795: Very large companies
CTM92840: Non-resident company landlords
Close section
CTM93000: The filing obligation
CTM93005: General
CTM93020: Specified and return periods
CTM93030: Filing date - definition
CTM93040: Filing date - detail
CTM93050: Filing date - examples
CTM93060: Filing date - further time
CTM93070: Filing date - Companies Act extension
CTM93080: Delivery of return
CTM93090: Delivery of return - content
CTM93100: Delivery of return - interpretations
CTM93110: Delivery of return - Must include SA
CTM93120: Information about partnership income
CTM93140: Prescribed form of CT600
CTM93160: Substitute return forms
CTM93180: Accounts to be delivered
CTM93190: Period accounts to cover
CTM93200: Returns
CTM93210: Computations
CTM93220: Computations - in round thousands
CTM93230: Insurance companies
CTM93240: Overseas companies
CTM93250: Overseas companies - branches of
CTM93255: Overseas companies: otherwise within the charge to corporation tax
CTM93260: Unsatisfactory return and online filing
CTM93270: Unsatisfactory return - action to take
CTM93280: Estimated figures in returns
CTM93290: Estimated figures in returns - ICAEW Technical Release 12/92
CTM93300: Amended returns
CTM93330: Correction of return by HMRC
Close section
CTM94000: Penalties for late returns
CTM94005: General
CTM94010: Exceptions
CTM94020: Other types of penalty
CTM94050: Flat and higher rate penalties
CTM94060: Tax-related penalties
CTM94070: Amount of tax unpaid
CTM94080: Amount of tax unpaid - surrender of refund
CTM94090: Interaction of flat-rate & tax-related penalties
CTM94100: Companies Act extension
CTM94110: Companies Act extension - Overseas company
CTM94120: Companies Act extension - examples
CTM94130: Further time
CTM94140: Reasonable excuse
CTM94150: Reasonable excuse - grounds
CTM94200: Determination - Procedure
CTM94210: Determination - general rules
CTM94220: Determination - Appeals against
CTM94230: Determination - postponement provisions not applicable
CTM94240: More than one tax-related penalty for the same accounting period
CTM94250: Time limits
CTM95005: Discovery Assessments and Determinations General
Close section
CTM95300: Revenue determination
CTM95305: Power to make
CTM95310: Timing
CTM95320: Period for which made
CTM95330: When of no effect
CTM95340: Review
CTM95350: Filing date ascertainable?
CTM95360: Partial compliance with notice to deliver
CTM95370: Dates payable
CTM95380: Enforcement power
CTM95390: Time limit
CTM95400: Superseded by SA
CTM95410: Proceedings for tax started - company makes return
CTM95430: Negative amounts
CTM95440: Conclusiveness of amount
Close section
CTM97000: Group relief - general
CTM97002: Introduction
CTM97005: Claim to be made in return
CTM97010: Specify amount claimed
CTM97015: Amount to be claimed
CTM97020: Consent to surrender
CTM97025: Surrender of losses
CTM97030: Allowing the claim
CTM97035: Withdrawal of consent
CTM97040: Simplified arrangement
CTM97045: Time limit
CTM97050: Time limit - enquiry cases
CTM97055: Time limit - late claims
CTM97060: Time limit - late claims - SP5/01 - text
CTM97065: Time limit - late claims - SP5/01 - guidance on
CTM97070: Surrendered amount reduced
Close section
CTM97400: Group payment arrangements
CTM97405: Introduction
CTM97410: Administration
CTM97420: Companies eligible
CTM97430: Copy of the contract
CTM97440: Copy of the guidance notes
CTM97450: Pre-acceptance checks
CTM97460: Accounting periods & group payment periods
CTM97470: Newly acquired company - example
CTM97480: Short accounting period - example
CTM97490: Payment of tax
CTM97500: Closing date
CTM97510: Overpayment
CTM97520: Rolling forward
CTM97530: Removal by agreement
CTM97540: Removal by contract
CTM97550: Participating companies list
CTM97560: Apportion payments at closure
CTM97570: Late filing penalties
CTM97580: Termination - Clause 18
CTM97590: Termination - Clause 19
Close section
CTM97600: Group relief - simplified arrangements
CTM97610: Time limits for claims
CTM97650: General
CTM97660: Authorised company
CTM97670: Authorising company
CTM97680: Members of the same group
CTM97690: Application to set up an arrangement
CTM97700: Application to join an existing arrangement
CTM97710: Written statement of claims and surrenders
CTM97730: Time limit for decision on an application
CTM97740: Refusal of an application
CTM97750: Partial acceptance of an application
CTM97760: Termination of arrangement and exclusion of a company from arrangement
CTM97770: Making and withdrawing claims to group relief and amending returns
CTM97780: Special rules for consortium members
CTM97790: Change in members of a consortium
Close section
CTM98000: Capital allowances
CTM98005: General
CTM98010: Claim must be made in return
CTM98020: Time limit
CTM98030: Time limit - extended in enquiry
CTM98040: Time limit - when not extended
CTM98050: Time limit - HMRC may extend
CTM98060: Consequential assessments or amendments
Close section
CTM98200: Loans to participators
CTM98205: General
CTM98210: Due date
CTM98215: Claims to relief - General
CTM98220: Claims to relief - Action to take
CTM98225: Claims to relief - Giving effect
CTM98230: Claims to relief - Giving effect - examples
CTM98235: Quarterly instalments - Credit or debit interest
CTM98240: Late payment interest
CTM98245: Repayment interest
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