Deduction for deemed employment payments for corporation tax purposesU.K.
10(1)This paragraph applies for the purpose of calculating for corporation tax purposes the profits of a business carried on by a managed service company (“the MSC”) which is treated as making a deemed employment payment in connection with the business.U.K.
(2)A deduction is allowed for—
(a)the amount of the deemed employment payment, and
(b)the amount of any employer's national insurance contributions paid by the MSC in respect of it.
(3)The deduction is allowed for the period of account in which the deemed employment payment is treated as made.
(4)If the MSC is a partnership, the amount of the deduction allowed under sub-paragraph (2) is limited to the amount that reduces the profits of the partnership for the period of account to nil.
(5)No deduction in respect of—
(a)the deemed employment payment, or
(b)any employer's national insurance contributions paid by the MSC in respect of it,
may be made except in accordance with this paragraph.
(6)In this paragraph “business”, “deemed employment payment”, “employer's national insurance contributions” and “managed service company” have the same meanings as in Chapter 9 of Part 2 of ITEPA 2003.