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Corporation Tax Act 2009

  • Explanatory Notes Table of contents

Please note:

All reference to 'Parts' and 'sections' are from the Corporation Tax Act 2009. For other versions of these Explanatory Notes, see More Resources.

  1. Introduction

    1. Summary

    2. Background

      1. The Tax Law Rewrite project

      2. Steering Committee

      3. Consultative Committee

      4. Consultation

    3. This Act

      1. The end of the Schedules

      2. Features of the Act

    4. Glossary

  2. Commentary on Sections

    1. Part 1: Introduction

      1. Section 1: Overview of Act

    2. Part 2: Charge to corporation tax: basic provisions

      1. Chapter 1: The charge to corporation tax

        1. Overview

          1. Section 2: Charge to corporation tax

          2. Section 3: Exclusion of charge to income tax

          3. Section 4: Exclusion of charge to capital gains tax

          4. Section 5: Territorial scope of charge

          5. Section 6: Profits accruing in fiduciary or representative capacity

          6. Section 7: Profits accruing under trusts

          7. Section 8: How tax is charged and assessed

      2. Chapter 2: Accounting periods

        1. Overview

          1. Section 9: Beginning of accounting period

          2. Section 10: End of accounting period

          3. Section 11: Companies with more than one accounting date

          4. Section 12: Companies being wound up

      3. Chapter 3: Company residence

        1. Overview

          1. Section 13: Overview of Chapter

          2. Section 14: Companies incorporated in the United Kingdom

          3. Section 15: Continuation of residence established under common law

          4. Section 16: SEs which transfer registered office to the United Kingdom

          5. Section 17: SCEs which transfer registered office to the United Kingdom

          6. Section 18: Companies treated as non-UK resident under double taxation arrangements

      4. Chapter 4: Non-UK resident companies: chargeable profits

        1. Overview

          1. Section 19: Chargeable profits

          2. Section 20: Profits attributable to permanent establishment: introduction

          3. Section 21: The separate enterprise principle

          4. Section 22: Transactions treated as being on arm’s length terms

          5. Section 23: Provision of goods or services for permanent establishment

          6. Section 24: Application to insurance companies

          7. Section 25: Non-UK resident banks: introduction

          8. Section 26: Transfer of financial assets

          9. Section 27: Loans: attribution of financial assets and profits arising

          10. Section 28: Borrowing: permanent establishment acting as agent or intermediary

          11. Section 29: Allowable deductions

          12. Section 30: Restriction on deductions: costs

          13. Section 31: Restriction on deductions: payments in respect of intangible assets

          14. Section 32: Restriction on deductions: interest or other financing costs

      5. Chapter 5: Supplementary

        1. Section 33: Trade includes office

    3. Part 3: Trading income

      1. Overview

        1. Chapter 1: Introduction

          1. Section 34: Overview of Part

        2. Chapter 2: Income taxed as trade profits

          1. Overview

            1. Section 35: Charge to tax on trade profits

            2. Section 36: Farming and market gardening

            3. Section 37: Commercial occupation of woodlands

            4. Section 38: Commercial occupation of land other than woodlands

            5. Section 39: Profits of mines, quarries and other concerns

            6. Section 40: Credit unions

            7. Section 41: Effect of company starting or ceasing to be within charge to corporation tax

            8. Section 42: Tied premises

            9. Section 43: Caravan sites where trade carried on

            10. Section 44: Surplus business accommodation

            11. Section 45: Payments for wayleaves

        3. Chapter 3: Trade profits: basic rules

          1. Section 46: Generally accepted accounting practice

          2. Section 47: Losses calculated on same basis as profits

          3. Section 48: Receipts and expenses

          4. Section 49: Items treated as receipts and expenses

          5. Section 50: Animals kept for trade purposes

          6. Section 51: Relationship between rules prohibiting and allowing deductions

          7. Section 52: Apportionment etc of profits and losses to accounting period

        4. Chapter 4: Trade profits: rules restricting deductions

          1. Overview

            1. Section 53: Capital expenditure

            2. Section 54: Expenses not wholly and exclusively for trade and unconnected losses

            3. Section 55: Bad debts

            4. Section 56: Car or motor cycle hire

            5. Section 57: Car or motor cycle hire: supplementary

            6. Section 58: Hiring cars (but not motor cycles) with low CO2 emissions before 1 April 2013

            7. Section 59: Patent royalties

            8. Section 60: Expenditure on integral features

        5. Chapter 5: Trade profits: rules allowing deductions

          1. Overview

            1. Section 61: Pre-trading expenses

            2. Section 62: Tenants under taxed leases: introduction

            3. Section 63: Tenants occupying land for purposes of trade treated as incurring expenses

            4. Section 64: Limit on deductions if tenant entitled to mineral extraction allowance

            5. Section 65: Tenants dealing with land as property employed for purposes of trade

            6. Section 66: Restrictions on section 63 expenses: lease premium receipts

            7. Section 67: Restrictions on section 63 expenses: lease of part of premises

            8. Section 68: Replacement and alteration of trade tools

            9. Section 69: Payments for restrictive undertakings

            10. Section 70: Employees seconded to charities and educational establishments

            11. Section 71: Educational establishments

            12. Section 72: Payroll deduction schemes: contributions to agents’ expenses

            13. Section 73: Counselling and other outplacement services

            14. Section 74: Retraining courses

            15. Section 75: Retraining courses: recovery of tax

            16. Sections 76 to 81: Redundancy payments etc

              1. Overview

            17. Section 76: Redundancy payments and approved contractual payments

            18. Section 77: Payments in respect of employment wholly in employer’s trade

            19. Section 78: Payments in respect of employment in more than one capacity

            20. Section 79: Additional payments

            21. Section 80: Application of section 79 in cases involving partnerships

            22. Section 81: Payments made by the Government

            23. Section 82: Contributions to local enterprise organisations or urban regeneration companies

            24. Section 83: Meaning of “local enterprise organisation”

            25. Section 84: Approval of local enterprise agencies

            26. Section 85: Supplementary provisions with respect to approvals

            27. Section 86: Meaning of “urban regeneration company”

            28. Section 87: Expenses of research and development

            29. Section 88: Payments to research associations, universities etc

            30. Section 89: Expenses connected with patents

            31. Section 90: Expenses connected with designs or trade marks

            32. Section 91: Payments to Export Credits Guarantee Department

            33. Section 92: Levies etc under FISMA 2000

        6. Chapter 6: Trade profits: receipts

          1. Overview

            1. Section 93: Capital receipts

            2. Section 94: Debts incurred and later released

            3. Section 95: Acquisition of trade: receipts from transferor’s trade

            4. Section 96: Reverse premiums

            5. Section 97: Excluded cases

            6. Section 98: Tax treatment of reverse premiums

            7. Section 99: Arrangements not at arm’s length

            8. Section 100: Connected persons and property arrangements

            9. Section 101: Distribution of assets of mutual concerns

            10. Section 102: Industrial development grants

            11. Section 103: Sums recovered under insurance policies etc

            12. Section 104: Repayments under FISMA 2000

        7. Chapter 7: Trade profits: gifts to charities etc

          1. Section 105: Gifts of trading stock to charities etc

          2. Section 106: Meaning of “designated educational establishment”

          3. Section 107: Gifts of medical supplies and equipment

          4. Section 108: Receipt of benefits by donor or connected person

        8. Chapter 8: Trade profits: herd basis rules

          1. Overview

            1. Section 109: Election for application of herd basis rules

            2. Section 110: Meaning of “animal”, “herd”, “production herd” etc

            3. Section 111: Other interpretative provisions

            4. Section 112: Initial cost of herd and value of herd

            5. Section 113: Addition of animals to herd

            6. Section 114: Replacement of animals in herd

            7. Section 115: Amount of receipt if old animal slaughtered under disease control order

            8. Section 116: Sale of animals from herd

            9. Section 117: Sale of whole or substantial part of herd

            10. Section 118: Acquisition of new herd begun within 5 years of sale

            11. Section 119: Section 118: sale for reasons outside farmer’s control

            12. Section 120: Replacement of part sold begun within 5 years of sale

            13. Section 121: Section 120: sale for reasons outside farmer’s control

            14. Section 122: Herd basis elections

            15. Section 123: Five year gap in which no production herd kept

            16. Section 124: Slaughter under disease control order

            17. Section 125: Preventing abuse of the herd basis rules

            18. Section 126: Information if election made

            19. Section 127: Further assessment etc if herd basis rules apply

        9. Chapter 9: Trade profits: other specific trades

          1. Overview

            1. Section 128: Taxation of amounts taken to reserves

            2. Section 129: Conversion etc of securities held as circulating capital

            3. Section 130: Traders receiving distributions etc

            4. Section 131: Incidental costs of issuing qualifying shares

            5. Section 132: Dividends etc granted by industrial and provident societies

            6. Section 133: Annual payments paid by a credit union

            7. Section 134: Purchase or sale of woodlands

            8. Section 135: Relief in respect of mineral royalties

            9. Section 136: Lease premiums etc: reduction of receipts

            10. Section 137: Mineral exploration and access

            11. Section 138: Payments by companies liable to pool betting duty

            12. Section 139: Deduction for deemed employment payment

            13. Section 140: Special rules for partnerships

            14. Section 141: Deduction for deemed employment payments

            15. Section 142: Deduction for site preparation expenditure

            16. Section 143: Allocation of site preparation expenditure

            17. Section 144: Site preparation expenditure: supplementary

            18. Section 145: Site restoration payments

            19. Section 146: Cemeteries and crematoria: introduction

            20. Section 147: Deduction for capital expenditure

            21. Section 148: Allocation of ancillary capital expenditure

            22. Section 149: Exclusion of expenditure met by subsidies

            23. Section 150: Revenue nature of expenditure

            24. Section 151: Allocation of expenditure

            25. Section 152: Interpretation of sections 150 and 151

            26. Section 153: Reserves of marketing authorities and certain other statutory bodies

            27. Section 154: Conditions to be met by reserve fund

            28. Section 155: Interpretation of sections 153 and 154

        10. Chapter 10: Trade profits: changes in trading stock

          1. Overview

            1. Section 156: Meaning of “trading stock”

            2. Section 157: Trading stock appropriated by trader

            3. Section 158: Trading stock supplied by trader

            4. Section 159: Disposals not made in the course of trade

            5. Section 160: Acquisitions not made in the course of trade

            6. Section 161: Transfer pricing rules to take precedence

        11. Chapter 11: Trade profits: valuation of stock on cessation of trade

          1. Overview

            1. Section 162: Valuation of trading stock on cessation

            2. Section 163: Meaning of “trading stock”

            3. Section 164: Basis of valuation of trading stock

            4. Section 165: Sale basis of valuation: sale to unconnected person

            5. Section 166: Sale basis of valuation: sale to connected person

            6. Section 167: Sale basis of valuation: election by connected persons

            7. Section 168: Connected persons

            8. Section 169: Cost to buyer of stock valued on sale basis of valuation

            9. Section 170: Meaning of “sale” and related expressions

            10. Section 171: Determination of questions

        12. Chapter 12: Deductions from profits: unremittable amounts

          1. Overview

            1. Section 172: Application of Chapter

            2. Section 173: Relief for unremittable amounts

            3. Section 174: Restrictions on relief

            4. Section 175: Withdrawal of relief

        13. Chapter 13: Disposal and acquisition of know-how

          1. Overview

            1. Section 176: Meaning of “know-how” etc

            2. Section 177: Disposal of know-how if trade continues to be carried on

            3. Section 178: Disposal of know-how as part of disposal of all or part of a trade

            4. Section 179: Seller controlled by buyer etc

        14. Chapter 14: Adjustment on change of basis

          1. Overview

            1. Section 180: Application of Chapter

            2. Section 181: Giving effect to positive and negative adjustments

            3. Section 182: Calculation of the adjustment

            4. Section 183: No adjustment for certain expenses previously brought into account

            5. Section 184: Cases where adjustment not required until assets realised or written off

            6. Section 185: Change from realisation basis to mark to market

            7. Section 186: Election for spreading if section 185 applies

            8. Section 187: Transfer of insurance business

        15. Chapter 15: Post-cessation receipts

          1. Overview

            1. Section 188: Charge to tax on post-cessation receipts

            2. Section 189: Extent of charge to tax

            3. Section 190: Basic meaning of “post-cessation receipt”

            4. Section 191: Other rules about what counts as post-cessation receipts

            5. Section 192: Debts paid after cessation

            6. Section 193: Debts released after cessation

            7. Section 194: Transfer of rights if transferee does not carry on trade

            8. Section 195: Transfer of trading stock

            9. Section 196: Allowable deductions

            10. Section 197: Further rules about allowable deductions

            11. Section 198: Election to carry back

            12. Section 199: Deductions already made are not displaced

            13. Section 200: Election given effect in accounting period in which receipt is received

        16. Chapter 16: Priority rules

          1. Section 201: Provisions which must be given priority over this Part

    4. Part 4: Property income

      1. Overview

        1. Chapter 1: Introduction

          1. Section 202: Overview of Part

        2. Chapter 2: Property businesses

          1. Section 203: Overview of Chapter

          2. Section 204: Meaning of “property business”

          3. Section 205: UK property business

          4. Section 206: Overseas property business

          5. Section 207: Meaning of “generating income from land”

          6. Section 208: Activities not for generating income from land

        3. Chapter 3: Profits of property businesses: basic rules

          1. Section 209: Charge to tax on profits of a property business

          2. Section 210: Profits of a property business: application of trading income rules

          3. Section 211: Loan relationships and derivative contracts

          4. Section 212: Items treated as receipts and expenses

          5. Section 213: Certain amounts brought into account under Part 3

          6. Section 214: Relationship between rules prohibiting and allowing deductions

        4. Chapter 4: Profits of property businesses: lease premiums etc

          1. Overview

            1. Section 215: Overview of Chapter

            2. Section 216: Meaning of “short-term lease”

            3. Section 217: Lease premiums

            4. Section 218: Amount treated as lease premium where work required

            5. Section 219: Sums payable instead of rent

            6. Section 220: Sums payable for surrender of lease

            7. Section 221: Sums payable for variation or waiver of terms of lease

            8. Section 222: Assignments for profit of lease granted at undervalue

            9. Section 223: Provisions supplementary to section 222

            10. Section 224: Sales with right to reconveyance

            11. Section 225: Sale and leaseback transactions

            12. Section 226: Provisions supplementary to sections 224 and 225

            13. Section 227: Circumstances in which additional calculation rule applies

            14. Section 228: The additional calculation rule

            15. Section 229: The additional calculation rule: special cases

            16. Section 230: Meaning of “unused amount” and “unreduced amount”

            17. Section 231: Deductions for expenses under section 232

            18. Section 232: Tenants under taxed leases treated as incurring expenses

            19. Section 233: Restrictions on section 232 expenses: the additional calculation rule

            20. Section 234: Restrictions on section 232 expenses: lease of part of premises

            21. Section 235: Limit on reductions and deductions

            22. Section 236: Payment of tax by instalments

            23. Section 237: Statement of accuracy for purposes of section 222

            24. Section 238: Claim for repayment of tax payable by virtue of section 224

            25. Section 239: Claim for repayment of tax payable by virtue of section 225

            26. Section 240: Appeals against proposed determinations

            27. Section 241: Section 240: supplementary

            28. Section 242: Determination by tribunal

            29. Section 243: Rules for determining effective duration of lease

            30. Section 244: Applying the rules in section 243

            31. Section 245: Information about effective duration of lease

            32. Section 246: Provisions about premiums

            33. Section 247: Interpretation

        5. Chapter 5: Profits of property businesses: other rules about receipts and deductions

          1. Overview

            1. Section 248: Furnished lettings

            2. Section 249: Acquisition of business: receipts from transferor’s UK property business

            3. Section 250: Reverse premiums

            4. Section 251: Deduction for expenditure on energy-saving items

            5. Section 252: Restrictions on relief

            6. Section 253: Regulations

            7. Section 254: Deduction for expenditure on sea walls

            8. Section 255: Transfer of interest in premises

            9. Section 256: Ending of lease of premises

            10. Section 257: Transfer involving person within the charge to income tax

            11. Section 258: Relief in respect of mineral royalties

            12. Section 259: Nature of item apportioned on sale of estate or interest in land

            13. Section 260: Mutual business

            14. Section 261: Adjustment on change of basis

            15. Section 262: Giving effect to positive and negative adjustments

            16. Section 263: Expenditure on integral features

        6. Chapter 6: Commercial letting of furnished holiday accommodation

          1. Overview

            1. Section 264: Overview of Chapter

            2. Section 265: Meaning of “commercial letting of furnished holiday accommodation”

            3. Section 266: Meaning of “relevant period” in sections 267 and 268

            4. Section 267: Meaning of “qualifying holiday accommodation”

            5. Section 268: Under-used holiday accommodation: averaging elections

            6. Section 269: Capital allowances and loss relief

        7. Chapter 7: Rent receivable in connection with a UK section 39(4) concern

          1. Overview

            1. Section 270: Charge to tax on rent receivable in connection with a UK section 39(4) concern

            2. Section 271: Meaning of “rent receivable in connection with a UK section 39(4) concern”

            3. Section 272: Deduction for management expenses of owner of mineral rights

            4. Section 273: Relief in respect of mineral royalties

            5. Section 274: Meaning of “mineral lease or agreement” and “mineral royalties”

            6. Section 275: Extended meaning of “mineral royalties” etc in Northern Ireland

            7. Section 276: Power to determine what counts as “mineral royalties”

        8. Chapter 8: Rent receivable for UK electric-line wayleaves

          1. Overview

            1. Section 277: Charge to tax on rent receivable for a UK electric-line wayleave

            2. Section 278: Meaning of “rent receivable for a UK electric-line wayleave”

            3. Section 279: Extent of charge to tax

        9. Chapter 9: Post-cessation receipts

          1. Overview

            1. Section 280: Charge to tax on post-cessation receipts

            2. Section 281: Extent of charge to tax

            3. Section 282: Basic meaning of “post-cessation receipt”

            4. Section 283: Other rules about what counts as a “post-cessation receipt”

            5. Section 284: Transfer of rights if transferee does not carry on UK property business

            6. Section 285: Allowable deductions

            7. Section 286: Election to carry back

        10. Chapter 10: Supplementary

          1. Section 287: Provisions which must be given priority over this Part

          2. Section 288: Priority between Chapters within this Part

          3. Section 289: Effect of company starting or ceasing to be within charge to corporation tax

          4. Section 290: Overseas property businesses and overseas land: adaptation of rules

          5. Section 291: Meaning of “lease” and “premises”

    5. Part 5: Loan Relationships

      1. Overview

        1. Chapter 1: Introduction

          1. Overview

            1. Section 292: Overview of Part

            2. Section 293: Construction of references to profits or losses from loan relationships

            3. Section 294: Matters treated as loan relationships

            4. Section 295: General rule: profits arising from loan relationships chargeable as income

            5. Section 296: Profits and deficits to be calculated using credits and debits given by this Part

            6. Section 297: Trading credits and debits to be brought into account under Part 3

            7. Section 298: Meaning of trade and purposes of trade

            8. Section 299: Charge to tax on non-trading profits

            9. Section 300: Method of bringing non-trading deficits into account

            10. Section 301: Calculation of non-trading profits and deficits from loan relationships: non-trading credits and debits

        2. Chapter 2 Basic definitions

          1. Overview

            1. Section 302: “Loan relationship”, “creditor relationship”, “debtor relationship”

            2. Section 303: “Money debt”

            3. Section 304: “Related transaction”

            4. Section 305: Payments, interest, rights and liabilities under a loan relationship

        3. Chapter 3: The credits and debits to be brought into account: general

          1. Overview

            1. Section 306: Overview of Chapter

            2. Section 307: General principles about the bringing into account of credits and debits

            3. Section 308: Amounts recognised in determining a company’s profit or loss

            4. Section 309: Companies without GAAP-compliant accounts

            5. Section 310: Power to make regulations about recognised amounts

            6. Section 311: Amounts not fully recognised for accounting purposes: introduction

            7. Section 312: Determination of credits and debits where amounts not fully recognised

            8. Section 313: Basis of accounting: “amortised cost basis”, “fair value accounting” and “fair value”

            9. Section 314: Power to make regulations about changes from amortised cost basis

            10. Section 315: Introduction to sections 316 to 319

            11. Section 316: Change of accounting policy involving change of value

            12. Section 317: Carrying value

            13. Section 318: Change of accounting policy following cessation of loan relationship

            14. Section 319: General power to make regulations about changes in accounting policy

            15. Section 320: Credits and debits treated as relating to capital expenditure

            16. Section 321: Credits and debits recognised in equity

            17. Section 322: Release of debts: cases where credits not required to be brought into account

            18. Section 323: Meaning of expressions relating to insolvency etc

            19. Section 324: Restriction on debits resulting from revaluation

            20. Section 325: Restriction on credits resulting from reversal of disallowed debits

            21. Section 326: Writing off government investments

            22. Section 327: Disallowance of imported losses etc

            23. Section 328: Exchange gains and losses

            24. Section 329: Pre-loan relationship and abortive expenses

            25. Section 330: Debits in respect of pre-trading expenditure

            26. Section 331: Company ceasing to be party to loan relationship

            27. Section 332: Repo, stock lending and other transactions

            28. Section 333: Company ceasing to be UK resident

            29. Section 334: Non-UK resident company ceasing to hold loan relationship for UK permanent establishment

        4. Chapter 4: Continuity of treatment on transfers within groups or on reorganisations

          1. Overview

            1. Section 335: Introduction to Chapter

            2. Section 336: Transfers of loans on group transactions

            3. Section 337: Transfers of loans on insurance business transfers

            4. Section 338: Meaning of company replacing another as party to loan relationship

            5. Section 339: Issues of new securities on certain cross-border reorganisations

            6. Section 340: Group transfers and transfers of insurance business: transfer at notional carrying value

            7. Section 341: Transferor using fair value accounting

            8. Section 342: Issues of new securities on reorganisations: disposal at notional carrying value

            9. Section 343: Receiving company using fair value accounting

            10. Section 344: Introduction

            11. Section 345: Transferee leaving group otherwise than because of exempt distribution

            12. Section 346: Transferee leaving group because of exempt distribution

            13. Section 347: Disapplication of Chapter where transferor party to avoidance

        5. Chapter 5: Connected companies relationships: introduction and general

          1. Overview

            1. Section 348: Introduction: meaning of “connected companies relationship”

            2. Section 349: Application of amortised cost basis to connected companies relationships

            3. Section 350: Companies beginning to be connected

            4. Section 351: Companies ceasing to be connected

            5. Section 352: Disregard of related transactions

        6. Chapter 6: Connected companies relationships: impairment losses and releases of debts

          1. Overview

            1. Section 353: Introduction to Chapter

            2. Section 354: Exclusion of debits for impaired or released connected companies debts

            3. Section 355: Cessation of connection

            4. Section 356: Exception to section 354: swapping debt for equity

            5. Section 357: Exception to section 354: insolvent creditors

            6. Section 358: Exclusion of credits on release of connected companies debts: general

            7. Section 359: Exclusion of credits on release of connected companies debts during creditor’s insolvency

            8. Section 360: Exclusion of credits on reversal of impairments of connected companies debts

            9. Section 361: Acquisition of creditor rights by connected company at undervalue

            10. Section 362: Parties becoming connected where creditor’s rights subject to impairment adjustment

            11. Section 363: Companies connected for sections 361 and 362

        7. Chapter 7: Group relief claims involving impaired or released consortium debts

          1. Overview

            1. Section 364: Introduction to Chapter

            2. Section 365: Reduction of impairment loss debits where group relief claimed

            3. Section 366: Effect where credit for release brought into account on amortised cost basis

            4. Section 367: Reduction of credits exceeding impairment losses

            5. Section 368: Reduction of claims where there are earlier net consortium debits

            6. Section 369: Carry forward of claims where there are no net consortium debits

            7. Section 370: Group accounting periods

            8. Section 371: Interpretation

        8. Chapter 8: Connected parties relationships: late interest

          1. Overview

            1. Section 372: Introduction to Chapter

            2. Section 373: Late interest treated as not accruing until paid in some cases

            3. Section 374: Connection between debtor and person standing in position of creditor

            4. Section 375: Loans to close companies by participators etc

            5. Section 376: Interpretation of section 375

            6. Section 377: Party to loan relationship having major interest in other party

            7. Section 378: Loans by trustees of occupational pension schemes

            8. Section 379: Persons indirectly standing in the position of creditor

        9. Chapter 9: Partnerships involving companies

          1. Overview

            1. Section 380: Partnerships involving companies

            2. Section 381: Determinations of credits and debits by company partners: general

            3. Section 382: Company partners using fair value accounting

            4. Section 383: Lending between partners and the partnership

            5. Section 384: Treatment of exchange gains and losses

            6. Section 385: Company partners’ shares where firm owns deeply discounted securities

        10. Chapter 10: Insurance companies

          1. Overview

            1. Section 386: Overview of Chapter

            2. Section 387: Treatment of deficit on basic life assurance and general annuity business: introduction

            3. Section 388: Basic rule: deficit set off against income and gains of deficit period

            4. Section 389: Claim to carry back deficit

            5. Section 390: Meaning of “available profits”

            6. Section 391: Carry forward of surplus deficit to next accounting period

            7. Section 392: Exclusion of loan relationships of members of Lloyd’s

            8. Section 393: General rules for some debtor relationships

            9. Section 394: Special rules for some debtor relationships

        11. Chapter 11: Other special kinds of company

          1. Overview

            1. Section 395: Investment trusts: profits or losses of a capital nature

            2. Section 396: Venture capital trusts: profits or losses of a capital nature

            3. Section 397: Credit unions

        12. Chapter 12: Special rules for particular kinds of securities

          1. Overview

            1. Section 398: Overview of Chapter

            2. Section 399: Index-linked gilt-edged securities: basic rules

            3. Section 400: Index-linked gilt-edged securities: adjustments for changes in index

            4. Section 401: Gilt strips

            5. Section 402: Market value of securities

            6. Section 403: Meaning of “strip”

            7. Section 404: Restriction on deductions etc relating to FOTRA securities

            8. Section 405: Certain non-UK residents with interest on 3½% War Loan 1952 Or After

            9. Section 406: Introduction

            10. Section 407: Postponement until redemption of debits for connected companies’ deeply discounted securities

            11. Section 408: Companies connected for section 407

            12. Section 409: Postponement until redemption of debits for close companies’ deeply discounted securities

            13. Section 410: Exceptions to section 409

            14. Section 411: Interpretation of section 409

            15. Section 412: Persons indirectly standing in the position of creditor

            16. Section 413: Issue of funding bonds

            17. Section 414: Redemption of funding bonds

            18. Section 415: Loan relationships with embedded derivatives

            19. Section 416: Election for application of sections 415 and 585

            20. Section 417: Further provisions about elections under section 416

            21. Section 418: Loan relationships treated differently by connected debtor and creditor

            22. Section 419: Section 418: supplementary

            23. Section 420: Assumptions where options etc apply

        13. Chapter 13: European cross-border transfers of business

          1. Overview

            1. Section 421: Introduction to Chapter

            2. Section 422: Transfer of loan relationship at notional carrying value

            3. Section 423: Transferor using fair value accounting

            4. Section 424: Reorganisations involving loan relationships

            5. Section 425: Original holder using fair value accounting

            6. Section 426: Tax avoidance etc

            7. Section 427: Procedure on application for clearance

            8. Section 428: Decision on application for clearance

            9. Section 429: Disapplication of Chapter where transparent entities involved

            10. Section 430: Interpretation

        14. Chapter 14: European cross-border mergers

          1. Overview

            1. Section 431: Introduction to Chapter

            2. Section 432: Meaning of “the transferee” and “transferor”

            3. Section 433: Transfer of loan relationship at notional carrying value

            4. Section 434: Transferor using fair value accounting

            5. Section 435: Reorganisations involving loan relationships

            6. Section 436: Original holder using fair value accounting

            7. Section 437: Tax avoidance etc

            8. Section 438: Disapplication of Chapter where transparent entities involved

            9. Section 439: Interpretation

        15. Chapter 15: Tax avoidance

          1. Overview

            1. Section 440: Overview of Chapter

            2. Section 441: Loan relationships for unallowable purposes

            3. Section 442: Meaning of “unallowable purpose”

            4. Section 443: Restriction of relief for interest where tax relief schemes involved

            5. Section 444: Transactions not at arm’s length: general

            6. Section 445: Disapplication of section 444 where Schedule 28AA to ICTA applies

            7. Section 446: Bringing into account adjustments made under Schedule 28AA to ICTA

            8. Section 447: Exchange gains and losses on debtor relationships: loans disregarded under Schedule 28AA to ICTA

            9. Section 448: Exchange gains and losses on debtor relationships: equity notes where holder associated with issuer

            10. Section 449: Exchange gains and losses on creditor relationships: no corresponding debtor relationship

            11. Section 450: Meaning of “corresponding debtor relationship”

            12. Section 451: Exception to section 449 where loan exceeds arm’s length amount

            13. Section 452: Exchange gains and losses where loan not on arm’s length terms

            14. Section 453: Connected parties deriving benefit from creditor relationships

            15. Section 454: Application of fair value accounting: reset bonds etc

            16. Section 455: Disposals for consideration not fully recognised by accounting practice

        16. Chapter 16: Non-trading deficits

          1. Overview

            1. Section 456: Introduction to Chapter

            2. Section 457: Basic rule for deficits: carry forward to accounting periods after deficit period

            3. Section 458: Claim to carry forward deficit to later accounting periods

            4. Section 459: Claim to set off deficit against profits of deficit period or earlier periods

            5. Section 460: Time limits and procedure for claims under section 459(1)

            6. Section 461: Claim to set off deficit against other profits for the deficit period

            7. Section 462: Claim to carry back deficit to earlier accounting periods

            8. Section 463: Profits available for relief under section 462

        17. Chapter 17: Priority rules

          1. Overview

            1. Section 464: Priority of this Part for corporation tax purposes

            2. Section 465: Exclusion of distributions except in tax avoidance cases

        18. Chapter 18: General and supplementary provisions

          1. Overview

            1. Section 466: Companies connected for an accounting period

            2. Section 467: Connections where partnerships are involved

            3. Section 468: Connection between companies to be ignored in some circumstances

            4. Section 469: Creditors who are financial traders

            5. Section 470: Section 469: supplementary provisions

            6. Section 471: Creditors who are insurance companies carrying on BLAGAB

            7. Section 472: Meaning of “control”

            8. Section 473: Meaning of “major interest”

            9. Section 474: Treatment of connected companies and partnerships for section 473

            10. Section 475: Meaning of expressions relating to exchange gains and losses

            11. Section 476: Other definitions

    6. Part 6: Relationships treated as loan relationships etc

      1. Overview

        1. Chapter 1: Introduction

          1. Section 477: Overview of Part

        2. Chapter 2: Relevant non-lending relationships

          1. Overview

            1. Section 478: Relevant non-lending relationships: introduction

            2. Section 479: Relevant non-lending relationships not involving discounts

            3. Section 480: Relevant non-lending relationships involving discounts

            4. Section 481: Application of Part 5 to relevant non-lending relationships

            5. Section 482: Miscellaneous rules about amounts to be brought into account because of this Chapter

            6. Section 483: Exchange gains and losses: amounts treated as money debts

            7. Section 484: Provision not at arm’s length: meaning of “interest” and “money debt”

            8. Section 485: Exclusion of debts where profits or losses within Part 7 or 8

            9. Section 486: Exclusion of exchange gains and losses in respect of tax debts etc

        3. Chapter 3: OEICs, unit trusts and offshore funds

          1. Overview

            1. Section 487: Overview of Chapter

            2. Section 488: Meaning of “open-ended investment company” etc

            3. Section 489: Meaning of “offshore fund” etc

            4. Section 490: Holdings in OEICs, unit trusts and offshore funds treated as creditor relationship rights

            5. Section 491: Holding coming within section 490: opening valuations

            6. Section 492: Disregard of investments made and liabilities incurred with avoidance intention etc

            7. Section 493: The qualifying investments test

            8. Section 494: Meaning of “qualifying investments”

            9. Section 495: Qualifying holdings

            10. Section 496: Meaning of “hedging relationship”

            11. Section 497: Power to change investments that are qualifying investments

        4. Chapter 4: Building societies

          1. Overview

            1. Section 498: Building society dividends and interest

        5. Chapter 5: Industrial and provident societies

          1. Overview

            1. Section 499: Industrial and provident society payments treated as interest under loan relationship

            2. Section 500: Exclusion of interest where failure to make return

        6. Chapter 6: Alternative finance arrangements

          1. Overview

            1. Section 501: Introduction to Chapter

            2. Section 502: Meaning of “financial institution”

            3. Section 503: Purchase and resale arrangements

            4. Section 504: Diminishing shared ownership arrangements

            5. Section 505: Deposit arrangements

            6. Section 506: Profit share agency arrangements

            7. Section 507: Investment bond arrangements

            8. Section 508: Provision not at arm’s length: exclusion of arrangements from sections 503 to 507

            9. Section 509: Application of Part 5: general

            10. Section 510: Application of Part 5 to particular alternative finance arrangements

            11. Section 511: Purchase and resale arrangements

            12. Section 512: Diminishing shared ownership arrangements

            13. Section 513: Other arrangements

            14. Section 514: Exclusion of alternative finance return from consideration for sale of assets

            15. Section 515: Diminishing shared ownership arrangements not partnerships

            16. Section 516: Treatment of principal under profit sharing agency arrangements

            17. Section 517: Treatment of bond-holder under investment bond arrangements

            18. Section 518: Investment bond arrangements: treatment as securities

            19. Section 519: Investment bond arrangements: other provisions

            20. Section 520: Provision not at arm’s length: non-deductibility of relevant return

            21. Section 521: Power to extend this Chapter to other arrangements

        7. Chapter 7: Shares with guaranteed returns etc

          1. Overview

            1. Section 522: Introduction to Chapter

            2. Section 523: Application of Part 5 to certain shares as rights under creditor relationship

            3. Section 524: Shares subject to outstanding third party obligations

            4. Section 525: Meaning of “interest-like investment”

            5. Section 526: Non-qualifying shares

            6. Section 527: The increasing value condition

            7. Section 528: Regulations about income-producing assets

            8. Section 529: The redemption return condition

            9. Section 530: The redemption return condition: excepted shares

            10. Section 531: The redemption return condition: unallowable purposes

            11. Section 532: The associated transactions condition

            12. Section 533: Power to change conditions for non-qualifying shares

            13. Section 534: Amounts to be brought into account where section 523 applies

            14. Section 535: Shares ceasing to be shares to which section 523 applies

        8. Chapter 8: Returns from partnerships

          1. Overview

            1. Section 536: Introduction to Chapter

            2. Section 537: Payments in return for capital contribution to partnership

            3. Section 538: Change of partnership shares

        9. Chapter 9: Manufactured interest etc

          1. Overview

            1. Section 539: Introduction to Chapter

            2. Section 540: Manufactured interest treated as interest under loan relationship

            3. Section 541: Debits for deemed interest under stock lending arrangements disallowed

        10. Chapter 10: Repos

          1. Overview

            1. Section 542: Introduction to Chapter

            2. Section 543: Meaning of creditor repo

            3. Section 544: Meaning of creditor quasi-repo

            4. Section 545: Ignoring effect on lender etc of sale of securities

            5. Section 546: Charge on lender for finance return in respect of the advance

            6. Section 547: Repo under arrangement designed to produce quasi-interest: tax avoidance

            7. Section 548: Meaning of debtor repo

            8. Section 549: Meaning of debtor quasi-repo

            9. Section 550: Ignoring effect on borrower of sale of securities

            10. Section 551: Relief for borrower for finance charges in respect of the advance

            11. Section 552: General provisions about arrangements

            12. Section 553: Persons buying or selling for others

            13. Section 554: Power to modify this Chapter

            14. Section 555: Cases where section 554 applies: non-standard repos

            15. Section 556: Meaning of securities and similar securities

            16. Section 557: Meaning of person receiving an asset

            17. Section 558: Interpretation of accounting expressions

            18. Section 559: Minor definitions

        11. Chapter 11: Investment life insurance contracts

          1. Overview

            1. Section 560: Introduction to Chapter

            2. Section 561: Meaning of “investment life insurance contract”

            3. Section 562: Contract to be loan relationship

            4. Section 563: Increased non-trading credits for BLAGAB and EEA taxed contracts

            5. Section 564: Section 563: interpretation

            6. Section 565: Relevant amount where the relevant company uses fair value accounting

            7. Section 566: Introduction

            8. Section 567: Gains on deemed surrenders to be brought into account on related transactions

            9. Section 568: Restriction on credits on old contracts: fair value accounting cases

            10. Section 569: Restriction on debits on old contracts: non-fair value accounting cases

    7. Part 7: Derivative contracts

      1. Overview

        1. Chapter 1: Introduction

          1. Section 570: Overview of Part

          2. Section 571: General rule: profits chargeable as income

          3. Section 572: Profits and losses to be calculated using credits and debits given by this Part

          4. Section 573: Trading credits and debits to be brought into account under Part 3

          5. Section 574: Non-trading credits and debits to be brought into account under Part 5

        2. Chapter 2: Contracts to which this Part applies

          1. Section 575: Overview of Chapter

          2. Section 576: “Derivative contract”

          3. Section 577: “Relevant contract”

          4. Section 578: Relevant contracts of a company and being party to such contracts

          5. Section 579: The accounting conditions

          6. Section 580: “Option”

          7. Section 581: “Future”

          8. Section 582: “Contract for differences”

          9. Section 583: “Underlying subject matter”

          10. Sections 584 to 586: Cases where companies treated as parties to relevant contracts

            1. Overview

          11. Section 584: Hybrid derivatives with embedded derivatives

          12. Section 585: Loan relationships with embedded derivatives

          13. Section 586: Other contracts with embedded derivatives

          14. Section 587: Contract relating to holding in OEIC, unit trust or offshore fund

          15. Section 588: Associated transaction treated as derivative contract

          16. Section 589: Contracts excluded because of underlying subject matter: general

          17. Section 590: Disregard of subordinate or small value underlying subject matter

          18. Section 591: Conditions A to E mentioned in section 589(5)

          19. Section 592: Embedded derivatives treated as meeting condition in section 591 etc

          20. Section 593: Contracts where part of underlying subject matter is excluded property

        3. Chapter 3: Credits and debits to be brought into account: general

          1. Section 594: Overview of Chapter

          2. Section 595: General principles about the bringing into account of credits and debits

          3. Section 596: Meaning of “related transaction”

          4. Section 597: Amounts recognised in determining a company’s profit or loss

          5. Section 598: Regulations about recognised amounts

          6. Section 599: Meaning of “amounts recognised for accounting purposes”

          7. Section 600: Contract which is or forms part of financial asset or liability

          8. Section 601: Contract relating to holding in OEIC, unit trust or offshore fund

          9. Section 602: Contract becoming one relating to holding in OEIC, unit trust or offshore fund

          10. Section 603: Associated transaction treated as derivative contract

          11. Section 604: Credits and debits treated as relating to capital expenditure

          12. Section 605: Credits and debits recognised in equity

          13. Section 606: Exchange gains and losses

          14. Section 607: Pre-contract or abortive expenses

          15. Section 608: Company ceasing to be party to derivative contract

          16. Section 609: Company ceasing to be UK resident

          17. Section 610: Non-UK resident company ceasing to hold derivative contract for UK permanent establishment

          18. Section 611: Release under statutory insolvency arrangement of liability under derivative contract

        4. Chapter 4: Further provision about credits and debits to be brought into account

          1. Section 612: Overview of Chapter

          2. Section 613: Introduction to sections 614 and 615

          3. Section 614: Change of accounting policy involving change of value

          4. Section 615: Change of accounting policy after ceasing to be party to derivative contract

          5. Section 616: Disapplication of fair value accounting

          6. Section 617: Election for section 616 not to apply

          7. Section 618: Elections under section 617: groups of companies

          8. Section 619: Partnerships involving companies

          9. Section 620: Determination of credits and debits by company partners

          10. Section 621: Company partners using fair value accounting

          11. Section 622: Contracts ceasing to be derivative contracts

          12. Section 623: Index-linked gilt-edged securities with embedded contracts for differences

        5. Chapter 5: Continuity of treatment on transfers within groups

          1. Section 624: Introduction to Chapter

          2. Section 625: Group member replacing another as party to derivative contract

          3. Section 626: Transactions to which section 625 applies

          4. Section 627: Meaning of company replacing another as party to derivative contract

          5. Section 628: Transferor using fair value accounting

          6. Section 629: Tax avoidance

          7. Section 630: Introduction to sections 631 and 632

          8. Section 631: Transferee leaving group otherwise than because of exempt distribution

          9. Section 632: Transferee leaving group because of exempt distribution

        6. Chapter 6: Special kinds of company

          1. Overview

            1. Section 633: Mutual trading companies

            2. Section 634: Insurance companies

            3. Section 635: Creditor relationships: embedded derivatives which are options

            4. Section 636: Modifications of Chapter 5

            5. Section 637: Investment trusts: profits or losses of a capital nature

            6. Section 638: Venture capital trusts: profits or losses of a capital nature

        7. Chapter 7: Chargeable gains arising in relation to derivative contracts

          1. Overview

            1. Section 639: Overview of Chapter

            2. Section 640: Credits and debits not to be brought into account under Part 5

            3. Section 641: Derivative contracts to be taxed on a chargeable gains basis

            4. Section 642: Exception from section 641

            5. Section 643: Contracts relating to land or certain tangible movable property

            6. Section 644: Income to be left out of account in determining whether section 643 applies

            7. Section 645: Creditor relationships: embedded derivatives which are options

            8. Section 646: Exclusions from section 645

            9. Section 647: Meaning of certain expressions in section 645

            10. Section 648: Creditor relationships: embedded derivatives which are exactly tracking contracts for differences

            11. Section 649: Meaning of certain expressions in section 648

            12. Section 650: Property based total return swaps

            13. Section 651: Credits and debits not to be brought into account under Part 3 or Part 5

            14. Section 652: Introduction to sections 653 to 655

            15. Section 653: Shares issued or transferred as a result of exercise of deemed option

            16. Section 654: Payment instead of disposal on exercise of deemed option

            17. Section 655: Ceasing to be party to debtor relationship when deemed option not exercised

            18. Section 656: Introduction to section 658

            19. Section 657: Meaning of “exactly tracking contract” in section 656

            20. Section 658: Chargeable gain or allowable loss treated as accruing

            21. Section 659: Meaning of “relevant credits” and “relevant debits”

        8. Chapter 8: Further provision about chargeable gains and derivative contracts

          1. Section 660: Contract relating to holding in OEIC, unit trust or offshore fund

          2. Section 661: Contract which becomes derivative contract

          3. Section 662: Contracts ceasing to be derivative contracts

          4. Section 663: Contracts to which section 641 applies

          5. Section 664: Meaning of certain expressions in section 663

          6. Section 665: Introduction to section 666

          7. Section 666: Allowable loss treated as accruing

          8. Section 667: Shares acquired on exercise of non-embedded option

          9. Section 668: Shares acquired on running of future to delivery

          10. Section 669: Meaning of G and L in sections 667 and 668

          11. Section 670: Treatment of net gains and losses on exercise of option

          12. Section 671: Meaning of G, L and CV in section 670

          13. Section 672: Treatment of net gains and losses on disposal of certain embedded derivatives

          14. Section 673: Meaning of G, L and CV in section 672

        9. Chapter 9: European cross-border transfers of business

          1. Overview

            1. Section 674: Introduction to Chapter

            2. Section 675: Transfer of derivative contract at notional carrying value

            3. Section 676: Transferor using fair value accounting

            4. Section 677: Tax avoidance etc

            5. Section 678: Procedure on application for clearance

            6. Section 679: Decision on application for clearance

            7. Section 680: Disapplication of Chapter where transparent entities involved

            8. Section 681: Interpretation

        10. Chapter 10: European cross-border mergers

          1. Overview

            1. Section 682: Introduction to Chapter

            2. Section 683: Meaning of “the transferee” and “transferor”

            3. Section 684: Transfer of derivative contract at notional carrying value

            4. Section 685: Transferor using fair value accounting

            5. Section 686: Tax avoidance etc

            6. Section 687: Disapplication of Chapter where transparent entities involved

            7. Section 688: Interpretation

        11. Chapter 11: Tax avoidance

          1. Section 689: Overview of Chapter

          2. Section 690: Derivative contracts for unallowable purposes

          3. Section 691: Meaning of “unallowable purpose”

          4. Section 692: Allowance of accumulated net losses

          5. Section 693: Bringing into account adjustments under Schedule 28AA to ICTA

          6. Section 694: Exchange gains and losses

          7. Section 695: Transfers of value to connected companies

          8. Section 696: Derivative contracts with non-UK residents

          9. Section 697: Exceptions to section 696

          10. Section 698: Disposals for consideration not fully recognised by accounting practice

        12. Chapter 12: Priority rules

          1. Section 699: Priority of this Part for corporation tax purposes

          2. Section 700: Relationship of this Part to Part 5: loan relationships

        13. Chapter 13: General and supplementary provisions

          1. Section 701: Power to amend some provisions

          2. Section 702: “Carrying value”

          3. Section 703: “Chargeable asset”

          4. Section 704: “Creditor relationship” and “debtor relationship”

          5. Section 705: Expressions relating to exchange gains and losses

          6. Section 706: “Excluded body”

          7. Section 707: “Hedging relationship”

          8. Section 708: “Plain vanilla contract”

          9. Section 709: “Securities house”

          10. Section 710: Other definitions

    8. Part 8: Intangible fixed assets

      1. Overview

        1. Chapter 1: Introduction

          1. Section 711: Overview of Part

          2. Section 712: “Intangible asset”

          3. Section 713: “Intangible fixed asset”

          4. Section 714: “Royalty”

          5. Section 715: Application of this Part to goodwill

          6. Section 716: “Recognised” amounts and “GAAP-compliant accounts”

          7. Section 717: Companies without GAAP-compliant accounts

          8. Section 718: GAAP-compliant accounts: reference to consolidated group accounts

          9. Section 719: Accounting value

        2. Chapter 2: Credits in respect of intangible fixed assets

          1. Section 720: Introduction

          2. Section 721: Receipts recognised as they accrue

          3. Section 722: Receipts in respect of royalties so far as not dealt with under section 721

          4. Section 723: Revaluation

          5. Section 724: Negative goodwill

          6. Section 725: Reversal of previous accounting loss

        3. Chapter 3: Debits in respect of intangible fixed assets

          1. Section 726: Introduction

          2. Section 727: References to expenditure on an asset

          3. Section 728: Expenditure written off as it is incurred

          4. Section 729: Writing down on accounting basis

          5. Section 730: Writing down at fixed rate: election for fixed-rate basis

          6. Section 731: Writing down at fixed rate: calculation

          7. Section 732: Reversal of previous accounting gain

        4. Chapter 4: Realisation of intangible fixed assets

          1. Section 733: Overview of Chapter

          2. Section 734: Meaning of “realisation”

          3. Section 735: Asset written down for tax purposes

          4. Section 736: Asset shown in balance sheet and not written down for tax purposes

          5. Section 737: Apportionment in case of part realisation

          6. Section 738: Asset not shown in balance sheet

          7. Section 739: Meaning of “proceeds of realisation”

          8. Section 740: Abortive expenditure on realisation

          9. Section 741: Meaning of “chargeable intangible asset” and “chargeable realisation gain”

        5. Chapter 5: Calculation of tax written-down value

          1. Overview

            1. Section 742: Asset written down on accounting basis

            2. Section 743: Asset written down at fixed rate

            3. Section 744: Effect of part realisation of asset

        6. Chapter 6: How credits and debits are given effect

          1. Section 745: Introduction

          2. Section 746: “Non-trading credits” and “non-trading debits”

          3. Section 747: Assets held for purposes of trade

          4. Section 748: Assets held for purposes of property business

          5. Section 749: Assets held for purposes of mines, transport undertakings, etc

          6. Section 750: Assets held for purposes falling within more than one section

          7. Section 751: Non-trading gains and losses

          8. Section 752: Charge to tax on non-trading gains on intangible fixed assets

          9. Section 753: Treatment of non-trading losses

        7. Chapter 7: Roll-over relief in case of realisation and reinvestment

          1. Section 754: The relief: the “old asset” and “other assets”

          2. Section 755: Conditions relating to the old asset and its realisation

          3. Section 756: Conditions relating to expenditure on other assets

          4. Section 757: Claim for relief

          5. Section 758: How the relief is given: general

          6. Section 759: Determination of appropriate proportion of cost and adjusted cost

          7. Section 760: References to cost of asset where asset affected by change of accounting policy

          8. Section 761: Declaration of provisional entitlement to relief

          9. Section 762: Realisation and reacquisition

          10. Section 763: Disregard of deemed realisations and reacquisitions

        8. Chapter 8: Groups of companies: introduction

          1. Section 764: Meaning of “company”, “group” and “subsidiary”

          2. Section 765: General rule: a company and its 75% subsidiaries form a group

          3. Section 766: Only effective 51% subsidiaries of principal company to be members of group

          4. Section 767: Principal company cannot be 75% subsidiary of another company

          5. Section 768: Company cannot be member of more than one group

          6. Section 769: Continuity of identity of group

          7. Section 770: Continuity where group includes an SE

          8. Section 771: Meaning of “effective 51% subsidiary”

          9. Section 772: Equity holders and profits or assets available for distribution

          10. Section 773: Supplementary provisions

        9. Chapter 9: Application of this Part to groups of companies

          1. Section 774: Overview of Chapter

          2. Section 775: Transfers within a group

          3. Section 776: Meaning of “tax-neutral” transfer

          4. Section 777: Relief on realisation and reinvestment: application to group member

          5. Section 778: Relief on reinvestment: acquisition of group company: introduction

          6. Section 779: Rules that apply to cases within section 778

          7. Section 780: Deemed realisation and reacquisition at market value

          8. Section 781: Character of credits and debits brought into account as a result of section 780

          9. Section 782: Certain transferees of businesses etc not treated as leaving group

          10. Section 783: Associated companies leaving group at the same time

          11. Section 784: Groups with a relevant connection

          12. Section 785: Principal company becoming member of another group

          13. Section 786: Character of credits and debits brought into account as a result of section 785

          14. Section 787: Company ceasing to be member of group because of exempt distribution

          15. Section 788: Provisions supplementing sections 780 to 787

          16. Section 789: Merger carried out for genuine commercial reasons

          17. Section 790: Provisions supplementing section 789

          18. Section 791: Application of roll-over relief in relation to degrouping charge

          19. Section 792: Reallocation of charge within group

          20. Section 793: Further requirements about elections under section 792

          21. Section 794: Application of roll-over relief in relation to reallocated charge

          22. Section 795: Recovery of charge from another group company or controlling director

          23. Section 796: Interpretation of section 795

          24. Section 797: Recovery under section 795: procedure etc

          25. Section 798: Recovery under section 795: time limit

          26. Section 799: Disregard of payments between group members for reliefs

        10. Chapter 10: Excluded assets

          1. Section 800: Introduction

          2. Section 801: Right to dispose of or acquire excluded asset also excluded

          3. Section 802: Effect of partial exclusion

          4. Section 803: Non-commercial purposes etc

          5. Section 804: Assets for which capital allowances previously made

          6. Section 805: Rights over tangible assets

          7. Section 806: Financial assets

          8. Section 807: Rights in companies, trusts etc

          9. Section 808: Assets representing production expenditure on films

          10. Section 809: Oil licences

          11. Section 810: Mutual trade or business

          12. Section 811: Sound recordings

          13. Section 812: Master versions of films

          14. Section 813: Computer software treated as part of cost of related hardware

          15. Section 814: Research and development

          16. Section 815: Election to exclude capital expenditure on software

          17. Section 816: Further provision about elections under section 815

        11. Chapter 11: Transfer of business or trade

          1. Section 817: Overview of Chapter

          2. Section 818: Company reconstruction involving transfer of business

          3. Section 819: European cross-border transfers of business: introduction

          4. Section 820: Transfer of assets on European cross-border transfer of business

          5. Section 821 European cross-border mergers: introduction

          6. Section 822 Transfer of assets on European cross-border merger

          7. Section 823 Interpretation of sections 821 and 822

          8. Section 824: Transfer of business of building society to company

          9. Section 825: Application of sections 780 and 785 where transfer within section 824 occurs

          10. Section 826: Amalgamation of, or transfer of engagements by, certain societies

          11. Section 827: Claims to postpone charge on transfer

          12. Section 828: Relief on transfer

          13. Section 829: Charge on subsequent realisations

          14. Section 830: Exclusion from section 829 of group transfers

          15. Section 831: The genuine commercial transaction requirement and clearance

          16. Section 832: Procedure on application for clearance

          17. Section 833: Decision on application for clearance

        12. Chapter 12: Related parties

          1. Section 834: Overview of Chapter

          2. Section 835: “Related party”

          3. Section 836: “Control”

          4. Section 837: “Major interest”

          5. Section 838: General rule

          6. Section 839: Rights and powers held jointly

          7. Section 840: Partnerships

          8. Section 841: “Participator” and “associate”

          9. Section 842: Introduction

          10. Section 843: Who are connected persons

        13. Chapter 13: Transactions between related parties

          1. Section 844: Overview of Chapter

          2. Section 845: Transfer between company and related party treated as at market value

          3. Section 846: Transfers not at arm’s length

          4. Section 847: Transfers involving other taxes

          5. Section 848: Tax-neutral transfers

          6. Section 849: Transfers involving gifts of business assets

          7. Section 850: Part realisation involving related party acquisition: exclusion of roll-over relief

          8. Section 851: Delayed payment of royalty by company to related party

        14. Chapter 14: Miscellaneous provisions

          1. Overview

            1. Section 852: Treatment of grants and other contributions to expenditure

            2. Section 853: Grants to be left out of account for tax purposes

            3. Section 854: Finance leasing etc

            4. Section 855: Further provision about regulations under section 854

            5. Section 856: Assets acquired or realised together

            6. Section 857: Deemed market value acquisition: adjustment where nil accounting value

            7. Section 858: Fungible assets

            8. Section 859: Asset ceasing to be chargeable intangible asset: deemed realisation at market value

            9. Section 860: Asset ceasing to be chargeable intangible asset: postponement of gain

            10. Section 861: Treatment of postponed gain on subsequent realisation

            11. Section 862: Treatment of postponed gain in other cases

            12. Section 863: Asset becoming chargeable intangible asset

            13. Section 864: Tax avoidance arrangements to be ignored

            14. Section 865: Debits for expenditure not generally deductible for tax purposes

            15. Section 866: Delayed payment of employees’ remuneration

            16. Section 867: Provisions supplementing section 866

            17. Section 868: Delayed payment of pension contributions

            18. Section 869: Bad debts etc

            19. Section 870: Assumptions for calculating chargeable profits

        15. Chapter 15: Adjustments on change of accounting policy

          1. Overview

            1. Section 871: Introduction to Chapter

            2. Section 872: Adjustments in respect of change

            3. Section 873: Effect of application of section 872 in later period and subsequently

            4. Section 874: Original asset not subject to fixed-rate writing down

            5. Section 875: Effect of application of section 874 in later period and subsequently

            6. Section 876: Original asset subject to fixed-rate writing down

            7. Section 877: Election for fixed-rate writing down in relation to resulting asset

            8. Section 878: Exclusion of credits or debits brought into account under other provisions

            9. Section 879: Subsequent events affecting asset subject to adjustment under this Chapter

        16. Chapter 16: Pre-FA 2002 assets etc

          1. Overview

            1. Section 880: Overview of Chapter

            2. Section 881: Meaning of “pre-FA 2002 assets”

            3. Section 882: Application of this Part to assets created or acquired on or after 1 April 2002

            4. Section 883: Assets treated as created or acquired when expenditure incurred

            5. Section 884: Internally-generated goodwill: time of creation

            6. Section 885: Certain other internally-generated assets: time of creation

            7. Section 886: Assets representing production expenditure on films: time of creation

            8. Section 887: General rule

            9. Section 888: Cases where chargeable gains rule applies

            10. Section 889: Cases where capital allowances general rule applies

            11. Section 890: Fungible assets: application of section 858

            12. Section 891: Realisation and acquisition of fungible assets

            13. Section 892: Certain assets acquired on transfer of business

            14. Section 893: Assets whose value derives from pre-FA 2002 assets

            15. Section 894: The preserved status conditions etc

            16. Section 895: Assets acquired in connection with disposals of pre-FA 2002 assets

            17. Section 896: Application to royalties

            18. Section 897: Application to pre-FA 2002 assets consisting of telecommunication rights

            19. Section 898: Relief where assets disposed of on or after 1 April 2002

            20. Section 899: Relief where degrouping charge on asset arises on or after 1 April 2002

            21. Section 900: Meaning of “chargeable asset within TCGA” in sections 898 and 899

        17. Chapter 17: Insurance companies

          1. Overview

            1. Section 901: Effect of application of the I minus E basis: non-trading amounts

            2. Section 902: Excluded assets

            3. Section 903: Elections to exclude capital expenditure on computer software

            4. Section 904: Transfers of life assurance business: transfers of assets treated as tax-neutral

            5. Section 905: Pre-FA 2002 assets: Lloyd’s syndicate capacity

        18. Chapter 18: Priority rules

          1. Section 906: Priority of this Part for corporation tax purposes

    9. Part 9: Intellectual property: know-how and patents

      1. Overview

        1. Chapter 1: Introduction

          1. Section 907: Overview of Part

        2. Chapter 2: Disposals of know-how

          1. Section 908: Charge to tax on profits from disposals of know-how

          2. Section 909: Exceptions to charge under section 908

          3. Section 910: Profits charged under section 908

        3. Chapter 3: Sales of Patent Rights

          1. Section 911: Overview of Chapter

          2. Section 912: Charge to tax on profits from sales of patent rights

          3. Section 913: Profits charged under section 912

          4. Section 914: UK resident companies: proceeds of sale not received in instalments

          5. Section 915: UK resident companies: proceeds of sale received in instalments

          6. Section 916: Non-UK resident companies: proceeds of sale not received in instalments

          7. Section 917: Non-UK resident companies: proceeds of sale received in instalments

          8. Section 918: Winding up of a body corporate

          9. Section 919: Deduction of tax from payments to non-UK resident companies

          10. Section 920: Adjustments where tax has been deducted

          11. Section 921: Licences connected with patents

          12. Section 922: Rights to acquire future patent rights

          13. Section 923: Sums paid for Crown use etc treated as paid under licence

        4. Chapter 4: Relief from corporation tax on patent income

          1. Section 924: Relief for expenses: patent income

          2. Section 925: How relief is given under section 924

        5. Chapter 5: Supplementary

          1. Section 926: Contributions to expenditure

          2. Section 927: Contributions not made by public bodies nor eligible for tax relief

          3. Section 928: Exchanges

          4. Section 929: Apportionment where property sold together

          5. Section 930: Questions about apportionments affecting two or more persons

          6. Section 931: Meaning of “capital sums” etc

    10. Part 10: Miscellaneous income

      1. Chapter 1: Introduction

        1. Section 932: Overview of Part

      2. Chapter 2: Dividends from non-UK resident companies

        1. Section 933: Charge to tax on dividends of non-UK resident companies

      3. Chapter 3: Beneficiaries’ income from estates in administration

        1. Overview

          1. Section 934: Charge to tax on estate income

          2. Section 935: Absolute, limited and discretionary interests

          3. Section 936: Meaning of “UK estate” and “foreign estate”

          4. Section 937: Absolute interests in residue

          5. Section 938: Meaning of “the administration period”, “the final accounting period” and “the final tax year”

          6. Section 939: Limited interests in residue

          7. Section 940: Discretionary interests in residue

          8. Section 941: UK estates

          9. Section 942: Foreign estates

          10. Section 943: Absolute interests

          11. Section 944: Limited interests

          12. Section 945: Discretionary interests

          13. Section 946: Applicable rate for grossing up basic amounts of estate income

          14. Section 947: Aggregate income of the estate

          15. Section 948: Assumed income entitlement

          16. Section 949: Residuary income of the estate

          17. Section 950: Shares of residuary income of estate

          18. Section 951: Reduction in share of residuary income of estate

          19. Section 952: Applicable rate for determining assumed income entitlement (UK estates)

          20. Section 953: Introduction

          21. Section 954: Successive absolute interests

          22. Section 955: Assumed income entitlement of holder of absolute interest following limited interest

          23. Section 956: Payments in respect of limited interests followed by absolute interests

          24. Section 957: Holders of limited interests

          25. Section 958: Basic amount of estate income: successive limited interests

          26. Section 959: Apportionments

          27. Section 960: Relief in respect of tax relating to absolute interests

          28. Section 961: Relief in respect of tax relating to limited or discretionary interests

          29. Section 962: Income from which basic amounts are treated as paid

          30. Section 963: Income treated as bearing income tax

          31. Section 964: Transfers of assets etc treated as payments

          32. Section 965: Assessments, adjustments and claims after the administration period

          33. Section 966: Power to obtain information from personal representatives and beneficiaries

          34. Section 967: Statements relating to estate income

          35. Section 968: Meaning of “personal representatives”

      4. Chapter 4: Income from holding an office

        1. Overview

          1. Section 969: Charge to tax on income from holding an office

          2. Section 970: Rule restricting deductions for bad debts

      5. Chapter 5: Distributions from unauthorised unit trusts

        1. Overview

          1. Section 971: Overview of Chapter

          2. Section 972: Charge to tax under this Chapter

          3. Section 973: Amount of income treated as received

      6. Chapter 6: Sales of foreign dividend coupons

        1. Overview

          1. Section 974: Charge to tax under this Chapter

          2. Section 975: Meaning of “foreign holdings” etc

      7. Chapter 7: Annual payments not otherwise charged

        1. Overview

          1. Section 976: Overview of Chapter

          2. Section 977: Charge to tax on annual payments not otherwise charged

          3. Section 978: Exemption for payments by persons liable to pool betting duty

      8. Chapter 8: Income not otherwise charged

        1. Overview

          1. Section 979: Charge to tax on income not otherwise charged

          2. Section 980: Exemption for commercial occupation of woodlands in UK

          3. Section 981: Exemption for gains on financial futures

      9. Chapter 9: Priority rules

        1. Section 982: Provisions which must be given priority over this Part

    11. Part 11: Relief for particular employee share acquisition schemes

      1. Overview

        1. Chapter 1: Share incentive plans

          1. Section 983: Overview of Chapter

          2. Section 984: Chapter to form part of SIP code etc

          3. Section 985: References to a deduction being allowed to a company

          4. Section 986: Treatment of receipts under Chapter

          5. Section 987: Deduction for costs of setting up an approved share incentive plan

          6. Section 988: Deductions for running expenses of an approved share incentive plan

          7. Section 989: Deduction for contribution to plan trust

          8. Section 990: Withdrawal of deduction under section 989

          9. Section 991: Another deduction to be allowed if all acquired shares are awarded

          10. Section 992: Award of shares to excluded employee

          11. Section 993: Termination plan notice

          12. Section 994: Deduction for providing free or matching shares

          13. Section 995: Deduction for additional expense in providing partnership shares

          14. Section 996: Shares excluded from sections 994 and 995

          15. Section 997: No deduction for expenses in providing dividend shares

          16. Section 998: Withdrawal of deductions if approval for share incentive plan withdrawn

        2. Chapter 2: SAYE option schemes, Company share option schemes and Employee share options trusts

          1. Section 999: Deduction for costs of setting up SAYE option scheme or CSOP scheme

          2. Section 1000: Deduction for costs of setting up employee share ownership trust

    12. Part 12: Other relief for employee share acquisitions

      1. Overview

        1. Chapter 1: Introduction

          1. Section 1001: Overview of Part

          2. Section 1002: “Employment”

          3. Section 1003: “Shares” etc

          4. Section 1004: Groups, consortiums and commercial associations of companies

          5. Section 1005: Other definitions

        2. Chapter 2: Relief if shares acquired by employee or other person

          1. Overview

            1. Section 1006: Overview of Chapter

            2. Section 1007: Basic requirements for relief under Chapter 2

            3. Section 1008: Conditions relating to shares acquired

            4. Section 1009: Conditions relating to employee’s income tax position

            5. Section 1010: Calculation of relief if shares are neither restricted nor convertible

            6. Section 1011: Calculation of relief if shares are restricted or convertible

            7. Section 1012: Reduction in amount of relief

            8. Section 1013: How the relief is given

        3. Chapter 3: Relief if employee or other person obtains option to acquire shares

          1. Overview

            1. Section 1014: Overview of Chapter

            2. Section 1015: Basic requirements for relief under Chapter 3

            3. Section 1016: Conditions relating to shares acquired

            4. Section 1017: Condition relating to employee’s income tax position

            5. Section 1018: Calculation of relief if shares are neither restricted nor convertible

            6. Section 1019: Calculation of relief if shares are restricted or convertible

            7. Section 1020: Reduction in amount of relief

            8. Section 1021: How the relief is given

            9. Section 1022: Takeover of company whose shares are subject to option

            10. Section 1023: Supplementary provision for purposes of section 1022

            11. Section 1024: Transfer of qualifying business by group transfers

        4. Chapter 4: Additional relief in cases involving restricted shares

          1. Overview

            1. Section 1025: Additional relief available if shares acquired are restricted shares

            2. Section 1026: Relief available on occurrence of chargeable event

            3. Section 1027: Relief available on death of employee

            4. Section 1028: Supplementary provision for purposes of sections 1026 and 1027

            5. Section 1029: Transfer of qualifying business by group transfers

        5. Chapter 5: Additional relief in cases involving convertible securities

          1. Overview

            1. Section 1030: Application of Chapter

            2. Section 1031: Additional relief available if shares acquired are convertible shares etc

            3. Section 1032: Meaning of “chargeable event”

            4. Section 1033: Relief available on occurrence of chargeable event

            5. Section 1034: Relief available following death of employee

            6. Section 1035: Supplementary provision for purposes of sections 1033 and 1034

            7. Section 1036: Transfer of qualifying business by group transfers

        6. Chapter 6 Relationship between relief under this Part and other reliefs

          1. Section 1037: Priority of Chapter 1 of Part 11

          2. Section 1038: Exclusion of other deductions

    13. Part 13: Additional relief for expenditure on research and development

      1. Overview

        1. Chapter 1: Introduction

          1. Section 1039: Overview of Part

          2. Section 1040: Relief may be available under more than one Chapter of Part

          3. Section 1041: “Research and development”

          4. Section 1042: “Relevant research and development”

        2. Chapter 2: Relief for SMEs: cost of R&D incurred by SME

          1. Overview

            1. Section 1043: Overview of Chapter

            2. Section 1044: Additional deduction in calculating profits of trade

            3. Section 1045: Alternative treatment for pre-trading expenditure: deemed trading loss

            4. Section 1046: Relief only available where company is going concern

            5. Section 1047: Elections under section 1045

            6. Section 1048: Treatment of deemed trading loss under section 1045

            7. Section 1049: Restriction on consortium relief

            8. Section 1050: R&D threshold

            9. Section 1051: Qualifying Chapter 2 expenditure

            10. Section 1052: Qualifying expenditure on in-house direct R&D

            11. Section 1053: Qualifying expenditure on contracted out R&D

            12. Section 1054: Entitlement to and payment of tax credit

            13. Section 1055: Meaning of “Chapter 2 surrenderable loss”

            14. Section 1056: Amount of trading loss which is “unrelieved”

            15. Section 1057: Tax credit only available where company is going concern

            16. Section 1058: Amount of tax credit

            17. Section 1059: Total amount of company’s PAYE and NIC liabilities

            18. Section 1060: Payment of tax credit

            19. Section 1061: Tax credit payment not income of company

            20. Section 1062: Restriction on losses carried forward where tax credit claimed

        3. Chapter 3: Relief for SMEs: R&D sub-contracted to SME

          1. Overview

            1. Section 1063: Additional deduction in calculating profits of trade

            2. Section 1064: R&D threshold

            3. Section 1065: Qualifying Chapter 3 expenditure

            4. Section 1066: Expenditure on sub-contracted R&D undertaken in-house

            5. Section 1067: Expenditure on sub-contracted R&D not undertaken in-house

        4. Chapter 4: Relief for SMEs: subsidised and capped expenditure on R&D

          1. Overview

            1. Section 1068: Additional deduction in calculating profits of trade

            2. Section 1069: R&D threshold

            3. Section 1070: Qualifying Chapter 4 expenditure

            4. Section 1071: Subsidised qualifying expenditure on in-house direct R&D

            5. Section 1072: Subsidised qualifying expenditure on contracted out R&D

            6. Section 1073: Capped R&D expenditure

        5. Chapter 5: Relief for large companies

          1. Overview

            1. Section 1074: Additional deduction in calculating profits of trade

            2. Section 1075: R&D threshold

            3. Section 1076: Qualifying Chapter 5 expenditure

            4. Section 1077: Qualifying expenditure on in-house direct R&D

            5. Section 1078: Qualifying expenditure on contracted out R&D

            6. Section 1079: Qualifying expenditure on contributions to independent R&D

            7. Section 1080: Entitlement to relief: I minus E basis

        6. Chapter 6: Chapters 2 to 5: further provision

          1. Section 1081: Insurance companies treated as large companies

          2. Section 1082: R&D expenditure of group companies

          3. Section 1083: Refunds of expenditure treated as income chargeable to tax

          4. Section 1084: Artificially inflated claims for relief or tax credit

        7. Chapter 7: Relief for SMEs and large companies: vaccine research etc

          1. Overview

            1. Section 1085: Overview of Chapter

            2. Section 1086: Meaning of “qualifying R&D activity”

            3. Section 1087: Deduction in calculating profits of trade

            4. Section 1088: Large companies: declaration about effect of relief

            5. Section 1089: SMEs: amount of deduction

            6. Section 1090: Modification of section 1089 for larger SMEs

            7. Section 1091: Large companies: amount of deduction

            8. Section 1092: SMEs: deemed trading loss for pre-trading expenditure

            9. Section 1093: Modification of section 1092 for larger SMEs

            10. Section 1094: Relief only available to SME where company is going concern

            11. Section 1095: Elections under section 1092

            12. Section 1096: Treatment of deemed trading loss under section 1092

            13. Section 1097: R&D threshold

            14. Section 1098: Meaning of “qualifying Chapter 7 expenditure”

            15. Section 1099: SMEs: qualifying expenditure “for” an accounting period

            16. Section 1100: Large companies: qualifying expenditure “for” an accounting period

            17. Section 1101: Qualifying expenditure on in-house direct R&D

            18. Section 1102: Qualifying expenditure on contracted out R&D

            19. Section 1103: Entitlement to and payment of tax credit

            20. Section 1104: Meaning of “Chapter 7 surrenderable loss”

            21. Section 1105: Amount of trading loss which is “unrelieved”

            22. Section 1106: Tax credit only available where company is going concern

            23. Section 1107: Amount of tax credit

            24. Section 1108: Total amount of company’s PAYE and NIC liabilities

            25. Section 1109: Payment of tax credit

            26. Section 1110: Tax credit payment not income of company

            27. Section 1111: Restriction on losses carried forward where tax credit claimed

            28. Section 1112: Artificially inflated claims for relief or tax credit

        8. Chapter 8: Cap on aid for R&D

          1. Overview

            1. Section 1113: Cap on R&D aid under Chapter 2 or 7

            2. Section 1114: Total R&D aid

            3. Section 1115: “The tax credits”

            4. Section 1116: “The actual reduction in tax liability”

            5. Section 1117: “The potential relief”

            6. Section 1118: “The notional relief”

        9. Chapter 9: Supplementary

          1. Overview

            1. Section 1119: “Small or medium-sized enterprise”

            2. Section 1120: Qualifications to section 1119

            3. Section 1121: “Larger SME”

            4. Section 1122: “Large company”

            5. Section 1123: “Staffing costs”

            6. Section 1124: Staffing costs: attributable expenditure

            7. Section 1125: “Software or consumable items”

            8. Section 1126: Software or consumable items: attributable expenditure

            9. Section 1127: “Qualifying expenditure on externally provided workers”

            10. Section 1128: “Externally provided worker”

            11. Section 1129: Qualifying expenditure on externally provided workers: connected persons

            12. Section 1130: Election for connected persons treatment

            13. Section 1131: Qualifying expenditure on externally provided workers: other cases

            14. Section 1132: External workers: attributable expenditure

            15. Section 1133: “Sub-contractor” and “sub-contractor payment”

            16. Section 1134: Qualifying element of sub-contractor payment: connected persons

            17. Section 1135: Election for connected persons treatment

            18. Section 1136: Qualifying element of sub-contractor payment: other cases

            19. Section 1137: Accounting periods: company not within charge to corporation tax

            20. Section 1138: “Subsidised expenditure”

            21. Section 1139: “Intellectual property”

            22. Section 1140: “Relevant payments to the subjects of a clinical trial”

            23. Section 1141: “Payment period”

            24. Section 1142: “Qualifying body”

    14. Part 14: Remediation of contaminated land

      1. Overview

        1. Chapter 1: Introduction

          1. Section 1143: Overview of Part

          2. Section 1144: “Qualifying land remediation expenditure”

          3. Section 1145: Land “in a contaminated state”

          4. Section 1146: “Relevant land remediation”

        2. Chapter 2: Reliefs for expenditure on contaminated land

          1. Section 1147: Deduction for capital expenditure

          2. Section 1148: Election under section 1147

          3. Section 1149: Additional deduction for qualifying land remediation expenditure

          4. Section 1150: No relief if company responsible for contamination

        3. Chapter 3: Land remediation tax credit

          1. Section 1151: Entitlement to and payment of tax credit

          2. Section 1152: Meaning of “qualifying land remediation loss”

          3. Section 1153: Amount of a loss which is “unrelieved”

          4. Section 1154: Amount of tax credit

          5. Section 1155: Payment of tax credit

          6. Section 1156: Tax credit payment not income of company

          7. Section 1157: Exclusion for capital gains purposes of certain expenditure

          8. Section 1158: Restriction on losses carried forward where tax credit claimed

        4. Chapter 4: Special provision for life assurance business

          1. Section 1159: Limitation on relief under Chapter 2

          2. Section 1160: Provision in respect of I minus E basis

          3. Section 1161: Relief in respect of I minus E basis: enhanced expenses payable

          4. Section 1162: Meaning of “qualifying Chapter 4 expenditure”

          5. Section 1163: No relief if company responsible for contamination

          6. Section 1164: Entitlement to tax credit

          7. Section 1165: Meaning of “qualifying life assurance business loss”

          8. Section 1166: Amount of tax credit

          9. Section 1167: Payment of tax credit etc

          10. Section 1168: Restriction on carrying forward expenses payable where tax credit claimed

        5. Chapter 5: Tax avoidance

          1. Section 1169: Artificially inflated claims for relief or tax credit

        6. Chapter 6: Supplementary

          1. Section 1170: “Staffing costs”

          2. Section 1171: Staffing costs attributable to relevant land remediation

          3. Section 1172: Expenditure on materials

          4. Section 1173: Expenditure incurred because of contamination

          5. Section 1174: Sub-contractor payments

          6. Section 1175: “Qualifying expenditure on sub-contracted land remediation”: connected persons

          7. Section 1176: “Qualifying expenditure on sub-contracted land remediation”: other cases

          8. Section 1177: “Subsidised expenditure”

          9. Section 1178: Persons having a “relevant connection” to a company

          10. Section 1179: Other definitions

    15. Part 15: Film production

      1. Overview

        1. Chapter 1: Introduction

          1. Section 1180: Overview of Part

          2. Section 1181: “Film” etc

          3. Section 1182: “Film production company”

          4. Section 1183: “Film-making activities” etc

          5. Section 1184: “Production expenditure”, “core expenditure” and “limited-budget film”

          6. Section 1185: “UK expenditure” etc

          7. Section 1186: “Qualifying co-production” and “co-producer”

          8. Section 1187: “Company tax return”

        2. Chapter 2: Taxation of activities of film production company

          1. Section 1188: Activities of film production company treated as a separate trade

          2. Section 1189: Calculation of profits or losses of separate film trade

          3. Section 1190: Income from the film

          4. Section 1191: Costs of the film

          5. Section 1192: When costs are taken to be incurred

          6. Section 1193: Pre-trading expenditure

          7. Section 1194: Estimates

        3. Chapter 3: Film tax relief

          1. Section 1195: Availability and overview of film tax relief

          2. Section 1196: Intended theatrical release

          3. Section 1197: British film

          4. Section 1198: UK expenditure

          5. Section 1199: Additional deduction for qualifying expenditure

          6. Section 1200: Amount of additional deduction

          7. Section 1201: Film tax credit claimable if company has surrenderable loss

          8. Section 1202: Surrendering of loss and amount of film tax credit

          9. Section 1203: Payment in respect of film tax credit

          10. Section 1204: No account to be taken of amount if unpaid

          11. Section 1205: Artificially inflated claims for additional deduction or film tax credit

          12. Section 1206: Confidentiality of information

          13. Section 1207: Wrongful disclosure

        4. Chapter 4: Film losses

          1. Section 1208: Application of sections 1209 and 1210

          2. Section 1209: Restriction on use of losses while film in production

          3. Section 1210: Use of losses in later periods

          4. Section 1211: Terminal losses

        5. Chapter 5: Provisional entitlement to relief

          1. Overview

            1. Section 1212: Introduction

            2. Section 1213: Certification as a British film

            3. Section 1214: The UK expenditure condition

            4. Section 1215: Film tax relief on basis that film is limited-budget film

            5. Section 1216: Time limit for amendments and assessments

    16. Part 16: Companies with investment business

      1. Overview

        1. Chapter 1: Introduction

          1. Section 1217: Overview of Part

          2. Section 1218: “Company with investment business” and “investment business”

        2. Chapter 2: Management expenses

          1. Section 1219: Expenses of management of a company’s investment business

          2. Section 1220: Meaning of “unallowable purpose”

          3. Section 1221: Amounts treated as expenses of management

          4. Section 1222: Income from a source not charged to tax

          5. Section 1223: Carrying forward expenses of management and other amounts

          6. Section 1224: Accounting period to which expenses are referable

          7. Section 1225: Accounts conforming with GAAP

          8. Section 1226: Accounts not conforming with GAAP

          9. Section 1227: Accounts not drawn up

          10. Section 1228: Credits that reverse debits

          11. Section 1229: Claw back of relief

          12. Section 1230: Meaning of “reversal amount”

          13. Section 1231: Absence of accounts

        3. Chapter 3: Amounts treated as expenses of management

          1. Section 1232: Chapter applies to amounts not otherwise relieved

          2. Section 1233: Excess capital allowances

          3. Sections 1234 to 1246

            1. Overview

          4. Section 1234: Payments for restrictive undertakings

          5. Section 1235: Employees seconded to charities and educational establishments

          6. Section 1236: Payroll deduction schemes

          7. Section 1237: Counselling and other outplacement services

          8. Section 1238: Retraining courses

          9. Sections 1239 to 1243: Redundancy payments etc

            1. Timing

            2. Just and reasonable apportionment

            3. Part of a business

            4. Devolution

          10. Section 1244: Contributions to local enterprise organisations or urban regeneration companies

          11. Section 1245: Payments to Export Credits Guarantee Department

          12. Section 1246: Levies under FISMA 2000

        4. Chapter 4: Rules restricting deductions

          1. Section 1247: Introduction

          2. Section 1248: Expenses in connection with arrangements for securing a tax advantage

          3. Section 1249: Unpaid remuneration

          4. Section 1250: Unpaid remuneration: supplementary

          5. Section 1251: Car or motor cycle hire

        5. Chapter 5: Companies with investment business: receipts

          1. Section 1252: Industrial development grants

          2. Section 1253: Contributions to local enterprise organisations or urban regeneration companies: disqualifying benefits

          3. Section 1254: Repayments under FISMA 2000

        6. Chapter 6: Supplementary

          1. Section 1255: Meaning of some accounting terms

    17. Part 17: Partnerships

      1. Overview

        1. Section 1256: Overview of Part

        2. Section 1257: General provisions

        3. Section 1258: Assessment of partnerships

        4. Section 1259: Calculation of firm’s profits and losses

      2. Changes in partnership

        1. Section 1260: Section 1259: supplementary

        2. Section 1261: Accounting periods of firms

        3. Section 1262: Allocation of firm’s profits or losses between partners

        4. Section 1263: Profit-making period in which some partners have losses

        5. Section 1264: Loss-making period in which some partners have profits

        6. Section 1265: Apportionment of profit share between partner’s accounting periods

        7. Section 1266: Resident partners and double taxation agreements

        8. Section 1267: Various rules for trades and property businesses

        9. Section 1268: Election for spreading under Chapter 14 of Part 3

        10. Section 1269: Interpretation of Sections 1267 and 1268

        11. Section 1270: Special provisions about farming and property income

        12. Section 1271: Sale of patent rights: effect of partnership changes

        13. Section 1272: Sale of patent rights: effect of later cessation of trade

        14. Section 1273: Limited liability partnerships

    18. Part 18: Unremittable income

      1. Overview

        1. Section 1274: Unremittable income: introduction

        2. Section 1275: Claim for relief for unremittable income

        3. Section 1276: Withdrawal of relief

        4. Section 1277: Income charged on withdrawal of relief after source ceases

        5. Section 1278: Valuing unremittable income

    19. Part 19: General exemptions

      1. Overview

        1. Section 1279: Exemption of profits from securities free of tax to residents abroad (“FOTRA securities”)

        2. Section 1280: Section 1279: supplementary provision

        3. Section 1281: Income from savings certificates

        4. Section 1282: Income from Ulster Savings Certificates

        5. Section 1283: Interest from tax reserve certificates

        6. Section 1284: Housing grants

        7. Section 1285: UK company distributions

        8. Section 1286: VAT repayment supplements

        9. Section 1287: Incentives to use electronic communications

    20. Part 20: General calculation rules

      1. Overview

      2. Chapter 1: Restriction of deductions

        1. Section 1288: Unpaid remuneration

        2. Section 1289: Unpaid remuneration: supplementary

        3. Employee benefit contributions

          1. Overview

          2. Section 1290: Employee benefit contributions

          3. Section 1291: Making of “employee benefit contributions”

          4. Section 1292: Provision of qualifying benefits

          5. Section 1293: Timing and amount of certain qualifying benefits

          6. Section 1294: Provision or payment out of employee benefit contributions

          7. Section 1295: Profits calculated before end of 9 month period

          8. Section 1296: Interpretation of sections 1290 to 1296

          9. Section 1297: Life assurance business

          10. Section 1298: Business entertainment and gifts

          11. Section 1299: Business entertainment: exceptions

          12. Section 1300: Business gifts: exceptions

          13. Section 1301: Restriction of deductions for annual payments

          14. Section 1302: Social security contributions

          15. Section 1303: Penalties, interest and VAT surcharges

          16. Section 1304: Crime-related payments

          17. Section 1305: Dividends and other distributions

      3. Chapter 2: Other general rules

        1. Section 1306: Losses calculated on same basis as miscellaneous income

        2. Section 1307: Apportionment etc of miscellaneous profits and losses to accounting period

        3. Section 1308: Expenditure brought into account in determining value of intangible asset

        4. Section 1309: Payments treated as made to visiting performers

    21. Part 21: Other general provisions

      1. Section 1310: Orders and regulations

      2. Section 1311: Apportionment to different periods

      3. Section 1312: Abbreviated references to Acts

      4. Section 1313: Activities in UK sector of continental shelf

      5. Section 1314: Meaning of “caravan”

      6. Section 1315: Claims and elections

      7. Section 1316: Meaning of “connected” persons and “control”

      8. Section 1317: Meaning of “farming” and related expressions

      9. Section 1318: Meaning of grossing up

      10. Section 1319: Other definitions

      11. Section 1320: Interpretation: Scotland

      12. Section 1321: Interpretation: Northern Ireland

      13. Section 1322: Minor and consequential amendments

      14. Section 1323: Power to make consequential provision

      15. Section 1324: Power to undo changes

      16. Section 1325: Transitional provisions and savings

      17. Section 1326: Repeals and revocations

      18. Section 1327: Index of defined expressions

      19. Section 1328: Extent

      20. Section 1329: Commencement

      21. Section 1330: Short title

    22. Schedule 1: Minor and consequential amendments

      1. Part 1: Income and Corporation Taxes Act 1988

        The charge to corporation tax

        1. Section 15 of ICTA

        2. Section 42 of ICTA

        3. Section 74 of ICTA

        4. Sections 76ZA to 76ZO of ICTA

        5. Section 84A of ICTA

        6. Section 86 of ICTA

        7. Section 89 of ICTA

        8. Section 92 of ICTA

        9. Section 101 of ICTA

        10. Section 116(4) of ICTA

        11. Section 119(2) of ICTA

        12. Section 209(6A) of ICTA

        13. Section 337A(2)(b) of ICTA

        14. Section 396 of ICTA

        15. Section 399 of ICTA

        16. Section 431 of ICTA

        17. Sections 586 and 587 of ICTA

        18. Section 695 of ICTA

        19. Section 779 of ICTA

        20. Section 781 of ICTA

        21. Section 782 of ICTA

        22. Section 785 of ICTA

        23. Section 798A of ICTA

        24. Sections 807B to 807G of ICTA

        25. Section 817 of ICTA

        26. Section 826(5A) of ICTA

        27. Section 834(1) of ICTA

        28. Section 834A of ICTA

        29. Section 842 of ICTA

        30. Section 843C of ICTA

        31. Paragraph 5 of Schedule 30 to ICTA

      2. Part 2: Other enactments

        1. TMA

          1. Section 12AE of TMA

          2. Section 19(2) of TMA

          3. Section 31(3) of TMA

          4. Section 42(7) of TMA

          5. Section 109A of TMA

        2. IHTA

          1. Section 91 of IHTA

        3. FA 1988

          1. Paragraph 3(1) of Schedule 12 to FA 1988

        4. TCGA

          1. Section 59 of TCGA

          2. Sections 116A and 116B of TCGA

          3. Sections 151E to 151G of TCGA

          4. Sections 156ZA and 156ZB of TCGA

          5. Section 158 of TCGA

          6. Section 286A of TCGA

        5. FA 1995

          1. Section 126 of FA 1995

          2. Section 127 of FA 1995

        6. FA 1998

          1. Paragraph 84 of Schedule 18 to FA 1998

        7. FA 1999

          1. Section 63 of FA 1999

        8. FA 2000

          1. Section 46 of FA 2000

        9. CAA

          1. Sections 108, 112, 115, 263 265, 559 and 577 of CAA

        10. FA 2002

          1. Paragraph 141 of Schedule 29 to FA 2002

        11. Energy Act 2004

          1. Sections 28 and 44 of the Energy Act 2004

        12. ITTOIA

          1. Section 48 of ITTOIA

          2. Section 49 of ITTOIA

          3. Sections 79, 79A and 80 of ITTOIA

          4. Sections 155 of ITTOIA

          5. Sections 175 to 184 of ITTOIA

          6. Section 303 of ITTOIA

          7. Section 860 of ITTOIA

          8. Section 749A of ITTOIA

          9. Sections 861 and 862 of ITTOIA

        13. FA 2005

          1. Section 49(2) of FA 2005

        14. FA 2006

          1. Sections 46 and 47 of FA 2006

          2. Section 121 of FA 2006

          3. Paragraph 28 of Schedule 10 to FA 2006

        15. ITA

          1. Section 835A of ITA

    23. Schedule 2: Transitionals and savings

    24. Part 1: General provisions

    25. Part 2: Changes in the law

    26. Part 3: Charge to corporation tax on income

      1. Effect of repeal of section 9(1) of ICTA on relevance of case law

    27. Part 5: Company residence: exceptions to section 14

    28. Part 6: Trading income

      1. Reserves of marketing authorities etc

    29. Part 7: Property income

      1. Lease premiums: time limits for claims for repayment of tax

    30. Part 8: Loan relationships

      1. Exemption for interest on tax overpaid for accounting periods ending before 1 July 1999

      2. 5½% Treasury Stock 2008-2012 not redeemed before 6 April 2009

    31. Part 10: Derivative contracts

      1. Extended meaning of reference in section 591(6)(b)

      2. Disapplication of section 645

      3. Existing assets representing creditor relationships: options

      4. Disapplication of section 648

      5. Existing assets representing creditor relationships: contracts for differences

      6. Disapplication of section 658

      7. Disapplication of section 661

      8. Disapplication of section 666

      9. Contracts which became derivative contracts on 16 March 2005

      10. Contracts which became derivative contracts on 28 July 2005

      11. Plain vanilla contracts which became derivative contracts before 30 December 2006

      12. Issuers of securities with embedded derivatives: deemed options

      13. Contract becoming derivative contract on 12 March 2008

      14. Avoidance relying on continuity of treatment provisions: transactions before 16 May 2008

      15. Disposals for consideration not fully recognised by accounting practice: disposals before 16 May 2008

      16. References to Companies Act 2006

      17. Repeal of provisions concerning exchange gains and losses from derivative contracts

    32. Part 14: Other relief for employee share acquisitions

      1. Accounting periods beginning before 1 January 2003

    33. Part 17: Film production

      1. Application of Part 15 etc to films that commenced principal photography before 1 January 2007 but were not completed before that date

    34. Part 19: Unremittable income

      1. Unremittable income that arose in an accounting period ending before 1 April 2009

    35. Part 21: Other provisions

      1. Miscellaneous profits and losses: apportionment to accounting periods ending before 1 April 2009

      2. Charge to tax under Case VI of Schedule D in subordinate legislation

    36. Schedule 3: Repeals and revocations

    37. Schedule 4: Index of defined expressions

  3. Commencement

  4. Hansard References

  5. Annex 1Minor Changes in the Law

  6. Annex 2Extra-Statutory Concessions, Case Law and List of Redundant Material Not Rewritten

  • Explanatory Notes Table of contents

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Explanatory Notes

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