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Corporation Tax Act 2009
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Changes over time for: Section 446
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Corporation Tax Act 2009, Section 446 is up to date with all changes known to be in force on or before 21 December 2024. There are changes that may be brought into force at a future date. Changes that have been made appear in the content and are referenced with annotations.
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Changes and effects yet to be applied to Section 446:
- s. 1058B(5)(ea) inserted by 2023 c. 20 Sch. para. 57
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Whole provisions yet to be inserted into this Act (including any effects on those provisions):
- s. 1058B(5)(ea) inserted by 2023 c. 20 Sch. para. 57
446Bringing into account adjustments made under [F1Part 4 of TIOPA 2010]U.K.
This section has no associated Explanatory Notes
(1)This section deals with the credits and debits which are to be brought into account for the purposes of this Part as a result of [F2Part 4 of TIOPA 2010] (provision not at arm's length) applying in relation to a company's loan relationships or related transactions.
(2)Subsection (3) applies if under [F3Part 4 of TIOPA 2010] an amount (“the imputed amount”) is treated as an amount of profits or losses arising to a company from any of its loan relationships or related transactions.
(3)Credits or debits relating to the imputed amount are to be brought into account for the purposes of this Part to the same extent as they would be in the case of an actual amount of such profits or losses.
(4)Subsection (5) applies if under [F4Part 4 of TIOPA 2010] an amount is treated as interest payable under any of a company's loan relationships.
(5)Credits or debits relating to that amount are to be brought into account for the purposes of this Part to the same extent as they would be in the case of an actual amount of such interest.
(6)Subsection (7) applies if under [F5Part 4 of TIOPA 2010] an amount is treated as expenses incurred by a company under or for the purposes of any of its loan relationships or related transactions.
(7)Debits relating to the amount are to be brought into account for the purposes of this Part to the same extent as they would be in the case of an actual amount of such expenses.
[F6(8)No credit is to be brought into account for the purposes of this Part to the extent that it corresponds to an amount which, as a result of the preceding provisions of this section, has not previously been brought into account as a debit.]
Textual Amendments
F1Words in s. 446 title substituted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 8 para. 134(2) (with Sch. 9 paras. 1-9, 22)
F2Words in s. 446(1) substituted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 8 para. 134(2) (with Sch. 9 paras. 1-9, 22)
F3Words in s. 446(2) substituted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 8 para. 134(2) (with Sch. 9 paras. 1-9, 22)
F4Words in s. 446(4) substituted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 8 para. 134(2) (with Sch. 9 paras. 1-9, 22)
F5Words in s. 446(6) substituted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 8 para. 134(2) (with Sch. 9 paras. 1-9, 22)
F6S. 446(8) inserted (with effect in accordance with Sch. 7 para. 12 of the amending Act) by Finance Act 2016 (c. 24), Sch. 7 para. 3
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