Corporation Tax Act 2010

  1. Introductory Text

  2. Part 1 Introduction

    1. 1.Overview of Act

  3. Part 2 Calculation of liability in respect of profits

    1. Chapter 1 Introduction

      1. 2.Overview of Part

    2. Chapter 2 Rates at which corporation tax on profits charged

      1. 3.Corporation tax rates

    3. Chapter 3 Calculation of amount to which rates applied

      1. 4.Amount of profits to which corporation tax rates applied

    4. Chapter 4 Currency

      1. The currency to be used in tax calculations

        1. 5.Basic rule: sterling to be used

        2. 6.UK resident company operating in sterling and preparing accounts in another currency

        3. 7.UK resident company operating in currency other than sterling and preparing accounts in another currency

        4. 8.UK resident company preparing accounts in currency other than sterling

        5. 9.Non-UK resident company preparing return of accounts in currency other than sterling

        6. 9A. Designated currency of a UK resident investment company

        7. 9B.Period for which an election under section 9A has effect

        8. 9C.Chargeable gains and losses of companies

      2. Translating amounts into other currencies

        1. 10.The equivalent in another currency of a sterling amount

        2. 11.Sterling equivalents: basic rule

        3. 12.Sterling equivalents: carried-back amounts

        4. 13.Sterling equivalents: carried-forward amounts

      3. Adjustment of sterling losses

        1. 14.Carried-back amounts

        2. 15.Carried-forward amounts

      4. Interpretation

        1. 16.Sections 13(2) and 15(5): profit against which carried-forward amount to be set off

        2. 17.Interpretation of Chapter

  4. Part 3 Companies with small profits

    1. The small profits rate

      1. 18.Profits charged at the small profits rate

    2. Marginal relief

      1. 19.Marginal relief

      2. 20.Company with only ring fence profits

      3. 21.Company with ring fence profits and other profits

      4. 22.The ring fence amount

      5. 23.The remaining amount

    3. The lower limit and the upper limit

      1. 24.The lower limit and the upper limit

      2. 25.Associated companies

      3. 26.Section 25(3): treatment of certain non-trading companies

      4. 27.Attribution to persons of rights and powers of their associates

      5. 28.Associated companies: fixed-rate preference shares

      6. 29.Association through a loan creditor

      7. 30.Association through a trustee

    4. Supplementary

      1. 31.Power to obtain information

      2. 32.Meaning of “augmented profits”

      3. 33.Interpretation of section 32(2) and (3)

      4. 34.Close investment-holding companies

  5. PART 3A Companies with small profits

    1. The standard small profits rate for non-ring fence profits

      1. 18A.Profits charged at the standard small profits rate

    2. Marginal relief

      1. 18B.Marginal relief for companies without ring fence profits

      2. 18C.Marginal relief for companies with ring fence profits

    3. The lower limit and the upper limit

      1. 18D.The lower limit and the upper limit

      2. 18E.Associated companies

      3. 18F.Section 18E(3): treatment of certain non-trading companies

      4. 18G.Attribution to persons of rights and powers of their partners

      5. 18H.Associated companies: fixed-rate preference shares

      6. 18I.Association through a loan creditor

      7. 18J.Association through a trustee

    4. Supplementary

      1. 18K.Power to obtain information

      2. 18L.Meaning of “augmented profits”

      3. 18M.Interpretation of section 18L(3)

      4. 18N.Close investment-holding companies

  6. Part 4 Loss relief

    1. Chapter 1 Introduction

      1. 35.Overview of Part

    2. Chapter 2 Trade losses

      1. Introduction

        1. 36.Introduction to Chapter

      2. Relief in loss-making period and carry back relief

        1. 37.Relief for trade losses against total profits

        2. 38.Limit on deduction if accounting period falls partly within 12 month period

        3. 39.Terminal losses: extension of periods for which relief may be given

        4. 40.Ring fence trades: extension of periods for which relief may be given

        5. 41.Sections 39 and 40: transfers of trade to obtain relief

        6. 42.Ring fence trades: further extension of period for relief

        7. 43.Claim period in case of ring fence or mineral extraction trades

        8. 44.Trade must be commercial or carried on for statutory functions

      3. Carry forward of trade loss relief

        1. 45.Carry forward of pre-1 April 2017 trade loss against subsequent trade profits

        2. 45A.Carry forward of post-1 April 2017 trade loss against total profits

        3. 45B.Carry forward of post-1 April 2017 trade loss against trade profits

        4. 45C.Re-application of section 45A if loss remains after previous application

        5. 45D.Application of section 45B if loss remains after application of section 45A

        6. 45E.Re-application of section 45B if loss remains after previous application

        7. 45F.Terminal losses: relief unrestricted by Part 7ZA and 7A

        8. 45G.Section 45F: accounting period falling partly within 3 year period

        9. 45H.Section 45F: transfers of trade to obtain relief

        10. 46.Use of trade-related interest and dividends if insufficient trade profits

        11. 47.Registered societies

      4. Restrictions on relief: farming or market gardening

        1. 48.Farming or market gardening

        2. 49.Reasonable expectation of profit

        3. 50.Cessation of trades

        4. 51.Companies treated as same person as individual

      5. Restrictions on relief: commodity futures

        1. 52.Dealings in commodity futures

      6. Other restrictions on relief

        1. 53.Leasing contracts and company reconstructions

        2. 54.Non-UK resident company: receipts of interest, dividends or royalties

    3. Chapter 3 Limited partners and members of limited liability partnerships

      1. Introduction

        1. 55.Introduction to Chapter

      2. Limited partners

        1. 56.Restriction on reliefs for limited partners

        2. 57.Meaning of “contribution to the firm”

        3. 58.Meaning of “limited partner”

      3. Members of LLPs

        1. 59.Restriction on relief for members of LLPs

        2. 60.Meaning of “contribution to the LLP”

        3. 61.Unrelieved losses brought forward

    4. Chapter 4 Property losses

      1. UK property businesses

        1. 62.Relief for losses made in UK property business

        2. 63.Company with investment business ceasing to carry on UK property business

        3. 64.UK property business to be commercial or carried on for statutory functions

        4. 65.UK furnished holiday lettings business treated as trade

      2. Overseas property businesses

        1. 66.Relief for losses made in overseas property business

        2. 67.Overseas property business to be commercial or carried on for statutory functions

        3. 67A. EEA furnished holiday lettings business treated as trade

      3. Insurance companies

        1. 67B.Exclusion in the case of property businesses of insurance companies

    5. Chapter 5 Losses on disposal of shares

      1. Share loss relief against income

        1. 68.Share loss relief

        2. 69.Eligibility conditions

        3. 70.Entitlement to claim

        4. 71.How relief works

        5. 72.Limit on deduction if accounting period falls partly within 12 month period

      2. Shares: subscription and disposal

        1. 73.Subscription for shares

        2. 74.Disposals of new shares

        3. 75.Limits on relief

        4. 76.Disposal of shares forming part of mixed holding

        5. 77.Section 76: supplementary

      3. Qualifying trading companies: the requirements

        1. 78.Qualifying trading companies

        2. 79.The trading requirement

        3. 80.Ceasing to meet trading requirement because of administration etc

        4. 81.The control and independence requirement

        5. 82.The qualifying subsidiaries requirement

        6. 83.The property managing subsidiaries requirement

        7. 84.The gross assets requirement

        8. 85.The unquoted status requirement

        9. 86.Power to amend requirements by Treasury order

      4. Qualifying trading companies: supplementary

        1. 87.Relief after an exchange of shares for shares in another company

        2. 88.Substitution of new shares for old shares

        3. 89.Deemed time of issue for certain shares

      5. Interpretation

        1. 90.Interpretation of Chapter

    6. Chapter 6 Losses from miscellaneous transactions

      1. 91.Relief for losses from miscellaneous transactions

    7. Chapter 7 Write-off of government investment

      1. 92.Loss relief to be reduced if government investment is written off

      2. 93.Groups of companies

      3. 94.Cases in which government investment is written off

      4. 95.Meaning of “carry-forward losses”

      5. 96.Interaction with other tax provisions

  7. Part 5 Group relief

    1. Chapter 1 Introduction

      1. 97.Introduction to Part

    2. Chapter 2 Surrender of company's losses etc for an accounting period

      1. Introduction

        1. 98.Overview of Chapter

      2. Basic provisions about surrendering losses and other amounts

        1. 99.Surrendering of losses and other amounts

        2. 100.Meaning of “trading loss”

        3. 101.Meaning of “capital allowance excess”

        4. 102.Meaning of “UK property business loss”

        5. 103.Meaning of “management expenses”

        6. 104.Meaning of “non-trading loss on intangible fixed assets”

      3. Restrictions on losses and other amounts that may be surrendered

        1. 105.Restriction on surrender of losses etc within section 99(1)(d) to (g)

        2. 106.Restriction on losses etc surrenderable by UK resident

        3. 107.Restriction on losses etc surrenderable by non-UK resident

        4. 108.Meaning of “non-UK profits”

        5. 109.Restriction on losses etc surrenderable by dual resident

        6. 110.Restriction on surrender of losses etc from alternative finance arrangements

    3. Chapter 3 Surrenders made by non-UK resident company resident or trading in the EEA

      1. Introduction

        1. 111.Overview of Chapter

        2. 112.EEA related definitions

      2. Basic provisions about surrendering losses and other amounts

        1. 113.Steps to determine extent to which loss etc can be surrendered

      3. Conditions that must be met

        1. 114.The equivalence condition

        2. 115.The EEA tax loss condition: companies resident in EEA territory

        3. 116.The EEA tax loss condition: companies not resident in EEA territory

        4. 117.The qualifying loss condition: general

        5. 118.The qualifying loss condition: relief for current and previous periods

        6. 119.The qualifying loss condition: relief for future periods

        7. 120.The qualifying loss condition: non-UK tax relief in another territory

        8. 121.The precedence condition

      4. Other rules, assumptions and exclusions

        1. 122.Assumptions to be made in recalculating EEA amount

        2. 123.Assumptions as to UK residence

        3. 124.Assumptions as to places in which activities carried on

        4. 125.Assumptions as to accounting periods

        5. 126.Assumptions in relation to capital allowances

        6. 127.Amounts excluded because of certain arrangements

        7. 128.Rules for recalculating EEA amount

    4. Chapter 4 Claims for group relief

      1. Introduction

        1. 129.Overview of Chapter

      2. Surrenderable amounts under Chapter 2

        1. 130.Group relief claims on amounts surrenderable under Chapter 2

        2. 131.The group condition

        3. 132.Consortium condition 1

        4. 133.Consortium conditions 2 and 3

        5. 134.Meaning of “UK related” company

        6. 134A.Companies “established in the EEA”

      3. Surrenderable amounts under Chapter 3

        1. 135.Group relief claims on amounts surrenderable under Chapter 3

        2. 136.The EEA group condition

      4. Giving of group relief

        1. 137.Deduction from total profits

      5. General limitation on amount of group relief to be given

        1. 138.Limitation on amount of group relief applying to all claims

        2. 139.Unused part of the surrenderable amounts

        3. 140.Unrelieved part of claimant company's available total profits

        4. 141.Sections 139 and 140: supplementary

        5. 142.Meaning of “the overlapping period”

      6. Limitations on group relief if claim based on consortium condition 1, 2 or 3

        1. 143.Condition 1: surrendering company owned by consortium

        2. 144.Condition 1: claimant company owned by consortium

        3. 145.Conditions 2 and 3: limitations in sections 143 and 144

        4. 146.Conditions 2 and 3: companies in link company's group

        5. 146A. Conditions 1 and 2: surrendering company not controlled by claimant company etc

        6. 146B. Conditions 1 and 3: claimant company not controlled by surrendering company etc

        7. 147.Conditions 1 and 2: surrenderable amounts including trading loss

        8. 148.Conditions 1 and 2: surrendering company in group of companies

        9. 149.Conditions 1 and 3: claimant company in group of companies

    5. Chapter 5 Subsidiaries, groups and consortiums

      1. Introduction

        1. 150.Overview of Chapter

      2. Explanations of terms

        1. 151.Meaning of “75% subsidiary” and “90% subsidiary”

        2. 152.Groups of companies

        3. 153.Companies owned by consortiums and members of consortiums

      3. Arrangements for transfers of companies

        1. 154.Arrangements for transfer of member of group of companies etc

        2. 155.Arrangements for transfer of company owned by consortium etc

        3. 155A.Certain arrangements not within sections 154 and 155

        4. 155B.Certain mortgage arrangements not within sections 154 and 155

        5. 156.Sections 154 and 155: supplementary

    6. Chapter 6 Equity holders and profits or assets available for distribution

      1. Introduction

        1. 157.Introduction to Chapter

      2. Equity holders

        1. 158.Meaning of “equity holder”

        2. 159.Use of relevant company's assets

        3. 160.Meaning of “ordinary shares”

        4. 161.Meaning of “restricted right to dividends”

        5. 162.Meaning of “normal commercial loan”

        6. 163.Normal commercial loans: company's results or value of assets

        7. 164.Sections 160 and 162: supplementary

        8. 164A.Loan forming part of tier two capital

      3. Company's entitlement to profits or assets available for distribution: basic provisions

        1. 165.Proportion of profits available for distribution to which company is entitled

        2. 166.Proportion of assets available for distribution to which company is entitled

        3. 167.Profits or assets available for distribution and entitlement: supplementary

        4. 168.Meaning of “the relevant accounting period”

      4. Company's entitlement to profits or assets available for distribution: supplementary

        1. 169.Application and interpretation of sections 170 to 182

        2. 170.Shares or securities with limited rights

        3. 171.Shares or securities with temporary rights

        4. 172.Company A's proportion if shares etc have temporary rights

        5. 173.Cases in which option arrangements are in place

        6. 174.Company A's proportion if option arrangements in place

        7. 174A.Certain option arrangements not within section 173

        8. 174B.Certain mortgage arrangements not within section 173

        9. 175.Cases in which both sections 170 and 172 apply

        10. 176.Cases in which both sections 170 and 174 apply

        11. 177.Cases in which both sections 172 and 174 apply

        12. 178.Cases in which sections 170, 172 and 174 all apply

        13. 179.Cases in which surrendering or claimant company is non-UK resident

        14. 180.Company A's proportion if non-UK resident involved

        15. 181.Assumptions to be applied if non-UK resident company involved

        16. 182.Assets etc referable to UK trade

    7. Chapter 7 Miscellaneous provisions and interpretation of Part

      1. Miscellaneous

        1. 183.Payments for group relief

        2. 184.References to “allowance” in CAA 2001

      2. Interpretation

        1. 185.“Trading company” and “holding company”

        2. 186.When activities of a company are double taxation exempt

        3. 187.“Non-UK tax”

        4. 188.Other definitions

  8. PART 5A Group relief for carried-forward losses

    1. CHAPTER 1 Introduction

      1. 188AA.Introduction to Part

    2. CHAPTER 2 Surrender of company's carried-forward losses etc

      1. 188BA.Overview of Chapter

      2. 188BB.Surrender of carried-forward losses and other amounts

      3. 188BC.Restriction on surrendering pre-1 April 2017 losses etc

      4. 188BD.Restriction where investment business has become small or negligible

      5. 188BE.Restriction where surrendering company could use losses etc itself

      6. 188BF.Restriction where surrendering company has no income-generating assets

      7. 188BG.Restrictions for certain insurance companies

      8. 188BH.Restriction on surrender of losses etc made when UK resident

      9. 188BI.Restriction on surrender of losses made when non-UK resident

      10. 188BJ.Restriction on surrender losses etc made when dual resident

    3. CHAPTER 3 Claims for group relief for carried-forward losses

      1. Introduction

        1. 188CA.Overview of Chapter

      2. Claiming group relief for carried-forward losses

        1. 188CB.Claims in relation to all the surrenderable amounts

        2. 188CC.Claims in relation to the surrenderable amounts that are attributable to a specified accounting period

        3. 188CD.Claim not allowed by company with unused carried-forward losses of its own

        4. 188CE.The group condition

        5. 188CF.Consortium condition 1

        6. 188CG.Consortium condition 2

        7. 188CH.Consortium condition 3

        8. 188CI.Consortium condition 4

        9. 188CJ.Meaning of “UK related” company

      3. Giving group relief for carried-forward losses

        1. 188CK.Deductions from total profits

    4. CHAPTER 4 Limitations on relief: claims under section 188CB

      1. Introduction

        1. 188DA.Overview

      2. General limitation on amount of relief

        1. 188DB.Limitation on amount of relief applying to all claims under section 188CB

        2. 188DC.Unused part of the surrenderable amounts

        3. 188DD.Claimant company's relevant maximum for overlapping period

        4. 188DE.Previously claimed group relief for carried-forward losses

        5. 188DF.Sections 188DC to 188DE: supplementary

        6. 188DG.Sections 188DC and 188DE: meaning of “the overlapping period”

      3. Further limitations on amount of relief if claim based on consortium conditions 1 or 2

        1. 188DH.Condition 1: ownership proportion

        2. 188DI.Condition 2: ownership proportion

        3. 188DJ.Condition 2: companies in link company's group

        4. 188DK.Conditions 1 and 2: claimant company not controlled by surrendering company etc

        5. 188DL.Conditions 1 and 2: claimant company in group of companies

    5. CHAPTER 5 Limitations on relief: claims under section 188CC

      1. Introduction

        1. 188EA.Overview of Chapter

      2. General limitation on amount of relief

        1. 188EB.Limitation on amount of relief applying to all claims under section 188CC

        2. 188EC.Unused part of surrenderable amounts attributable to specified loss-making period

        3. 188ED.Claimant company's relevant maximum for the overlapping period

        4. 188EE.Previously claimed group relief for carried-forward losses

        5. 188EF.The potential Part 5 group relief amount

        6. 188EG.Sections 188EC to 188EE: supplementary

        7. 188EH.Sections 188EC and 188EE: meaning of “the overlapping period”

      3. Further limitations on amount of relief that apply in particular cases

        1. 188EI.Condition 4: companies in link company's group

        2. 188EJ.Condition 3 or 4: surrendering company not controlled by claimant company etc

        3. 188EK.Condition 3 or 4: surrendering company in group of companies

    6. CHAPTER 6 Miscellaneous provisions and interpretation of Part

      1. Miscellaneous

        1. 188FA.Payments for group relief for carried-forward losses

      2. Interpretation

        1. 188FB.Subsidiaries, groups and consortiums

        2. 188FC.“Trading company” and “holding company”

        3. 188FD.Other definitions

  9. Part 6 Charitable donations relief

    1. Chapter 1 Nature of relief

      1. 189.Relief for qualifying charitable donations

      2. 190.Qualifying charitable donations: meaning

    2. Chapter 2 Certain payments to charity

      1. Qualifying payments

        1. 191.Qualifying payments

        2. 192.Condition as to repayment

        3. 193.Associated acquisition etc

        4. 194.Distributions

        5. 195.Associated benefits

        6. 196.Associated benefits: meaning

        7. 197.Restrictions on associated benefits

        8. 198.Payments and benefits linked to periods of less than 12 months

      2. Payment attributed to earlier period

        1. 199.Payment attributed to earlier accounting period

      3. Interpretation

        1. 200.Company wholly owned by a charity

        2. 201.Associated persons

        3. 202.“Charity”

        4. 202A.“Registered club”

    3. CHAPTER 2A Payments to community amateur sports clubs: anti-abuse

      1. 202B.Restriction on relief for payments to community amateur sports clubs

      2. 202C.“Inflated member-related expenditure”

    4. Chapter 3 Certain disposals to charity

      1. Amounts treated as qualifying charitable donations

        1. 203.Certain disposals of investments

        2. 204.Meaning of qualifying investment

        3. 205.Meaning of qualifying interest in land

        4. 206.The relievable amount

        5. 207.Incidental costs of making disposal

        6. 208.Consideration

      2. Value of net benefit to charity

        1. 209.Value of net benefit to charity

        2. 210.Market value of qualifying investments

        3. 210A.Acquisition value of qualifying investments

        4. 211.Meaning of “disposal-related obligation”

        5. 212.Meaning and amount of “disposal-related liability”

      3. Special provisions about qualifying interests in land

        1. 213.Certificate required from charity

        2. 214.Qualifying interests in land held jointly

        3. 215.Calculation of relievable amount etc where joint disposal of interest in land

        4. 216.Disqualifying events

      4. Interpretation

        1. 217.“Charity”

  10. PART 6A Relief for expenditure on grassroots sport

    1. 217A.Relief for expenditure on grassroots sport

    2. 217B.Meaning of qualifying expenditure on grassroots sport

    3. 217C.Meaning of qualifying sport body

    4. 217D.Relationship between this Part and Part 6

  11. Part 7 Community investment tax relief

    1. Chapter 1 Introduction

      1. CITR

        1. 218.Meaning of “CITR”

        2. 219.Eligibility for CITR

        3. 220.Form and amount of CITR

        4. 220A.Carry forward of CITR

        5. 220B.Limit on State aid

      2. Miscellaneous

        1. 221.Meaning of “making an investment”

        2. 222.Determination of “the invested amount”

        3. 223.Meaning of “the 5 year period” and “the investment date”

        4. 224.Overview of other Chapters of Part

    2. Chapter 2 Qualifying investments

      1. 225.Qualifying investments: introduction

      2. 226.Conditions to be met in relation to loans

      3. 227.Conditions to be met in relation to securities

      4. 228.Conditions to be met in relation to shares

      5. 229.Tax relief certificates

      6. 230.No pre-arranged protection against risks

    3. Chapter 3 General conditions

      1. 231.No control of CDFI by investor

      2. 232.Investor must have beneficial ownership

      3. 233.Investor must not be accredited

      4. 234.No acquisition of share in partnership

      5. 235.No tax avoidance purpose

    4. Chapter 4 Limitations on claims and attribution

      1. Limitations on claims

        1. 236.Loans: no claim after disposal or excessive repayments or receipts of value

        2. 237.Securities or shares: no claim after disposal or excessive receipts of value

        3. 238.No claim after loss of accreditation by the CDFI

        4. 239.Accreditation of investor

      2. Attribution

        1. 240.Attribution: general

        2. 241.Attribution: bonus shares

    5. Chapter 5 Withdrawal or reduction of CITR

      1. Introduction

        1. 242.Introduction to Chapter

      2. Disposals

        1. 243.Disposal of loan during 5 year period

        2. 244.Disposal of securities or shares during 5 year period

      3. Repayment of loans

        1. 245.Repayment of loan capital during 5 year period

      4. Receipts of value

        1. 246.Value received by investor during 6 year period: loans

        2. 247.Value received by investor during 6 year period: securities or shares

        3. 248.Receipts of insignificant value to be added together

        4. 249.When value is received

        5. 250.The amount of value received

        6. 251.Value received if there is more than one investment

        7. 252.Effect of receipt of value on future claims

        8. 253.Receipts of value by or from connected persons

      5. CITR not due

        1. 254.CITR subsequently found not to have been due

      6. Manner of withdrawal or reduction

        1. 255.Manner of withdrawal or reduction of CITR

    6. Chapter 6 Supplementary and general

      1. Alternative finance arrangements

        1. 256.Meaning of “loan” and “interest”

        2. 257.Purchase and resale arrangements

        3. 258.Deposit arrangements

        4. 259.Profit share agency arrangements

      2. Miscellaneous

        1. 260.Information to be provided by the investor

        2. 261.Disclosure

        3. 262.Nominees

        4. 263.Application for postponement of tax pending appeal

        5. 264.Identification of securities or shares on a disposal

      3. Definitions

        1. 265.Meaning of “issue of securities or shares”

        2. 266.Meaning of “disposal”

        3. 267.Construction of references to being “held continuously”

        4. 268.Meaning of “associate”

        5. 269.Minor definitions etc

  12. PART 7ZA Restrictions on obtaining certain deductions

    1. Introduction

      1. 269ZA.Overview of Part

    2. Restrictions on obtaining certain deductions

      1. 269ZB.Restriction on deductions from trading profits

      2. 269ZBA.Restriction on deductions from chargeable gains

      3. 269ZC.Restriction on deductions from non-trading profits

      4. 269ZD.Restriction on deductions from total profits

      5. 269ZDA.References to a company’s “deductions allowance”

      6. 269ZE.Restriction on deductions from total profits: insurance companies

    3. Relevant profits

      1. 269ZF.“Relevant trading profits”, “total relevant non-trading profits” etc

      2. 269ZFA.“Relevant profits”

    4. Modifications for certain insurance companies

      1. 269ZFB.Modifications for certain insurance companies

      2. 269ZFC.Restriction on deductions of non-BLAGAB allowable losses from BLAGAB chargeable gains

    5. Exclusion for certain general insurance companies

      1. 269ZG.General insurance companies: excluded accounting periods

      2. 269ZH.“Insolvency procedures”

      3. 269ZI.“Qualifying latent claims”

      4. 269ZJ.Exclusion of shock losses from restrictions

      5. 269ZK.Meaning of “shock loss”: requirement to make a claim

      6. 269ZL.Further provision about claims under section 269ZK

      7. 269ZM.Meaning of “solvency shock period”

      8. 269ZN.Determination of shock loss threshold

      9. 269ZO.Calculation of solvency loss

      10. 269ZP.Interpretation of sections 269ZJ to 269ZO

      11. 269ZQ.Power to amend

    6. Deductions allowance

      1. 269ZR.Deductions allowance for company in a group

      2. 269ZS.Group deductions allowance and the nominated company

      3. 269ZSA.Group allowance nomination: former groups

      4. 269ZT.Group allowance allocation statement: submission

      5. 269ZU.Group allowance allocation statement: submission of revised statement

      6. 269ZV.Group allowance allocation statement: requirements and effects

      7. 269ZVA.Group allowance allocation statement: former groups

      8. 269ZW.Deductions allowance for company not in a group

      9. 269ZWA.Increase of deductions allowance for insolvent companies

      10. 269ZX.Increase of deductions allowance in connection with onerous or impaired leases

      11. 269ZY.Meaning of “relevant reversal credit”

      12. 269ZYZA.Other relevant credits

      13. 269ZYA.Deductions allowance for company without a source of chargeable income

      14. 269ZYB.Provisional application of section 269ZYA

      15. 269ZZ.Company tax return to specify amount of deductions allowance

      16. 269ZZA.Excessive specifications of deductions allowance

      17. 269ZZB.Meaning of “group”

  13. PART 7A Banking companies

    1. CHAPTER 1 Introduction

      1. 269A.Overview of Part

    2. CHAPTER 2 Key definitions

      1. “Banking company”

        1. 269B.Meaning of “banking company”

        2. 269BA.Excluded entities

        3. 269BB.Relevant regulated activities

        4. 269BC.Banking companies: supplementary definitions

      2. “Group”

        1. 269BD.Meaning of “group”

      3. Powers to amend

        1. 269BE.Powers to amend

    3. CHAPTER 3 Restrictions on obtaining certain deductions

      1. Introduction

        1. 269C.Overview of Chapter

      2. Restrictions on obtaining certain deductions

        1. 269CA.Restriction on deductions for trading losses

        2. 269CB.Restriction on deductions for non-trading deficits from loan relationships

        3. 269CC.Restriction on deductions for management expenses etc

        4. 269CD.Relevant profits

      3. Losses to which restrictions do not apply

        1. 269CE.Losses arising before company began banking activity

        2. 269CF.Losses arising in company's start-up period

        3. 269CG.The “start-up period”

        4. 269CH.Losses covered by carried-forward loss allowance

        5. 269CI.Allocation of carried-forward loss allowance within a group

        6. 269CJ.Re-allocation of carried-forward loss allowance

      4. Anti-avoidance

        1. 269CK.Profits arising from tax arrangements to be disregarded

      5. Supplementary

        1. 269CL.When a company first begins to carry on relevant regulated activities

        2. 269CM.Joint venture companies

        3. 269CN.Other definitions

    4. CHAPTER 4 Surcharge on banking companies

      1. Overview

        1. 269D.Overview of Chapter

      2. The surcharge

        1. 269DA.Surcharge on banking companies

      3. Non-banking group relief

        1. 269DB.Meaning of “non-banking group relief”

        2. 269DBA.Meaning of “non-banking group relief for carried-forward losses”

      4. Non-banking or pre-2016 loss relief

        1. 269DC.Meaning of “non-banking or pre-2016 loss relief”

        2. 269DCA.Meaning of “non-banking transferred-in loss relief”

        3. 269DD.Meaning of “relevant transferred-out gain” and “non-banking transferred-in gain”

      5. The surcharge allowance

        1. 269DE.Surcharge allowance for banking company in a group containing other banking companies

        2. 269DF.Group surcharge allowance and the nominated company

        3. 269DG.Group allowance allocation statement: submission

        4. 269DH.Group allowance allocation statement: submission of revised statement

        5. 269DI.Group allowance allocation statement: requirements and effect

        6. 269DJ.Surcharge allowance for company not in a group containing other banking companies

        7. 269DK.Excessive specifications of available surcharge allowance

      6. Application of Corporation Tax Acts: administration, double taxation etc

        1. 269DL.Application of enactments applying to corporation tax: assessment, recovery, double taxation etc

        2. 269DM.Payments in respect of the surcharge: information to be provided

      7. Anti-avoidance

        1. 269DN.Profit and loss shifting to avoid or reduce surcharge liability

      8. Interpretation

        1. 269DO.Interpretation

  14. Part 8 Oil activities

    1. Chapter 1 Introduction

      1. 270.Overview of Part

    2. Chapter 2 Basic definitions

      1. 271.“Associated companies”

      2. 272.“Oil extraction activities”

      3. 273.“Oil rights”

      4. 274.“Oil-related activities”

      5. 275.“Ring fence income”

      6. 276.“Ring fence profits”

      7. 277.“Ring fence trade”

      8. 278.Other definitions

    3. Chapter 3 Deemed separate trade

      1. 279.Oil-related activities treated as separate trade

    4. CHAPTER 3A Rates at which corporation tax is charged on ring fence profits

      1. The rates

        1. 279A.Corporation tax rates on ring fence profits

      2. Marginal relief

        1. 279B.Company with only ring fence profits

        2. 279C.Company with ring fence profits and other profits

        3. 279D.The ring fence amount

        4. 279DA.The remaining amount

      3. The lower limit and the upper limit

        1. 279E.The lower limit and the upper limit

      4. Supplementary

        1. 279EA.Interpretation etc

      5. Related 51% group companies

        1. 279F.“Related 51% group company”

      6. Augmented profits

        1. 279G.“Augmented profits”

        2. 279H.Interpretation of section 279G(3) and (4)

    5. Chapter 4 Calculation of profits

      1. Oil valuation

        1. 280.Disposal to be valued by reference to section 2(5A) of OTA 1975

        2. 281.Valuation where market value taken into account under section 2 of OTA 1975

        3. 282.Valuation where disposal not sale at arm's length

        4. 283.Valuation where excess of nominated proceeds

        5. 284.Valuation where relevant appropriation but no disposal

        6. 285.Valuation where appropriation to refining etc

      2. Hire of relevant assets

        1. 285A.Restriction on hire etc of relevant assets to be brought into account

      3. Loan relationships

        1. 286.Restriction on debits to be brought into account

        2. 287.Restriction on credits to be brought into account

        3. 287A.Restriction where debits or credits relate to decommissioning security settlement

      4. Sale and lease-back

        1. 288.Sale and lease-back

      5. Regional development grants

        1. 289.Reduction of expenditure by reference to regional development grant

        2. 290.Adjustment as a result of regional development grant

      6. Tariff receipts etc

        1. 291.Tariff receipts etc

        2. 291A.Meaning of “tariff receipt”

        3. 291B.Tariff receipts: counteraction of avoidance arrangements

      7. Abandonment guarantees

        1. 292.Expenditure on abandonment guarantees

        2. 293.Relief for reimbursement expenditure under abandonment guarantees

        3. 294.Payment under abandonment guarantee not immediately applied

        4. 295.Amounts excluded from section 293(1)

      8. Abandonment expenditure

        1. 296.Introduction to section 297

        2. 297.Relief for expenditure incurred by a participator in meeting defaulter's abandonment expenditure

        3. 298.Reimbursement by defaulter in respect of certain abandonment expenditure

      9. Receipts arising from decommissioning

        1. 298A.Receipts arising from decommissioning

      10. Deduction of PRT in calculating income for corporation tax purposes

        1. 299.Deduction of PRT in calculating income for corporation tax purposes

        2. 300.Effect of repayment of PRT: general rule

        3. 301.Effect of repayment of PRT: special rule

      11. Interest on repayment of PRT or APRT

        1. 302.Interest on repayment of PRT or APRT

      12. Relief

        1. 303.Management expenses

        2. 303A.Introduction to sections 303B to 303D: post-1 April 2017 non-decommissioning losses of ring fence trades

        3. 303B.Carry forward of losses against subsequent profits

        4. 303C.Excess carried forward losses: relief against total profits

        5. 303D.Further carry forward against subsequent profits of loss not fully used

        6. 304.Losses

        7. 305.Group relief and group relief for carried-forward losses

        8. 306.Capital allowances

    6. Chapter 5 Ring fence expenditure supplement

      1. Introduction

        1. 307.Overview of Chapter

      2. Application and interpretation

        1. 308.Qualifying companies

        2. 309.Accounting periods

        3. 310.The relevant percentage

        4. 311.Limit on number etc of accounting periods for which supplement may be claimed

        5. 312.Qualifying pre-commencement expenditure

        6. 313.Unrelieved group ring fence profits for accounting periods

        7. 314.Taxable ring fence profits for an accounting period

      3. Pre-commencement supplement

        1. 315.Supplement in respect of a pre-commencement accounting period

        2. 316.The mixed pool of qualifying pre-commencement expenditure and supplement previously allowed

        3. 317.Reduction in respect of disposal receipts under CAA 2001

        4. 318.Reduction in respect of unrelieved group ring fence profits

        5. 318A.Adjustment of pool to remove pre-2013 expenditure after the initial 6 periods

        6. 319.The reference amount for a pre-commencement period

        7. 320.Claims for pre-commencement supplement

      4. Post-commencement supplement

        1. 321.Supplement in respect of a post-commencement period

        2. 322.Amount of post-commencement supplement for a post-commencement period

        3. 323.Ring fence losses

        4. 324.Special rule for straddling periods

        5. 325.The pool of ring fence losses and the pool of non-qualifying Schedule 19B losses

        6. 326.The ring fence pool

        7. 327.Reductions in respect of relief for carried-forward ring fence losses

        8. 328.Reductions in respect of unrelieved group ring fence profits

        9. 328A.Adjustment of pool to remove pre-2013 losses after the initial 6 periods

        10. 329.The reference amount for a post-commencement period

    7. CHAPTER 5A Extended ring fence expenditure supplement for onshore activities

      1. Introduction

        1. 329A.Overview of Chapter

      2. Application and interpretation

        1. 329B.Qualifying companies

        2. 329C.Onshore and offshore oil-related activities

        3. 329D.Accounting periods and straddling periods

        4. 329E.The relevant percentage

        5. 329F.Restrictions on accounting periods for which additional supplement may be claimed

        6. 329G.Qualifying pre-commencement onshore expenditure

        7. 329H.Unrelieved group ring fence profits

      3. Pre-commencement additional supplement

        1. 329I.Additional supplement in respect of a pre-commencement accounting period

        2. 329J.The mixed pool of qualifying pre-commencement onshore expenditure and supplement previously allowed

        3. 329K.Reduction in respect of disposal receipts under CAA 2001

        4. 329L.Reduction in respect of unrelieved group ring fence profits

        5. 329M.The reference amount for a pre-commencement period

      4. Post-commencement additional supplement

        1. 329N.Supplement in respect of post-commencement period

        2. 329O.Amount of post-commencement additional supplement for a post-commencement period

        3. 329P.Onshore ring fence losses

        4. 329Q.The onshore ring fence pool

        5. 329R.Reductions in respect of utilised onshore ring fence losses

        6. 329S.Reductions in respect of unrelieved group ring fence profits

        7. 329T.The reference amount for a post-commencement period

    8. Chapter 6 Supplementary charge in respect of ring fence trades

      1. 330.Supplementary charge in respect of ring fence trades

      2. 330ZA.Ordering of allowances

      3. 330A.Decommissioning expenditure taken into account in calculating ring fence profits

      4. 330B.Decommissioning expenditure taken into account for PRT purposes

      5. 330C.Meaning of “decommissioning expenditure”

      6. 331.Meaning of “financing costs” etc

      7. 332.Assessment, recovery and postponement of supplementary charge

    9. CHAPTER 6A Supplementary charge: investment allowance

      1. Introduction

        1. 332A.Overview

      2. “Qualifying oil field” and “investment expenditure”

        1. 332B.Meaning of “qualifying oil field”

        2. 332BA.Meaning of “investment expenditure”

      3. Investment allowance

        1. 332C.Generation of investment allowance

        2. 332CA.Expenditure incurred before field is determined

      4. Restrictions on relievable expenditure

        1. 332D.Expenditure on acquisition of asset: disqualifying conditions

        2. 332DA.Restriction where field qualified for field allowance as new field

        3. 332DB.Restriction where project in additionally-developed field qualified for field allowance

        4. 332DC.Restriction relating to fields qualifying for onshore allowance

      5. Reduction of adjusted ring fence profits

        1. 332E.Reduction of adjusted ring fence profits

        2. 332EA.Carrying forward of activated allowance

      6. Activated and unactivated allowance: basic calculation rules

        1. 332F.Activation of allowance: no change of equity share

        2. 332FA.The closing balance of unactivated allowance for an accounting period

        3. 332FB.Activation limit for former additionally-developed fields

        4. 332FC.Carrying forward of unactivated allowance

      7. Changes in equity share: reference periods

        1. 332G.Reference periods

      8. Changes in equity share: activation of allowance

        1. 332H.Activation of allowance: reference periods

        2. 332HA.Unactivated amounts attributable to a reference period

        3. 332HB.Carry-forward of unactivated allowance from a reference period

      9. Transfers of allowance on disposal of equity share

        1. 332I.Introduction to sections 332IA and 332IB

        2. 332IA.Reduction of allowance if equity is disposed of

        3. 332IB.Acquisition of allowance if equity acquired

      10. Miscellaneous

        1. 332J.Adjustments

        2. 332JA.Regulations amending specified percentages

      11. Interpretation

        1. 332K.When expenditure is incurred

        2. 332KA.Other definitions

    10. Chapter 7 REDUCTION OF SUPPLEMENTARY CHARGE FOR ELIGIBLE OIL FIELDS

      1. Reduction of adjusted ring fence profits

        1. 333.Reduction of adjusted ring fence profits

      2. Pool of field allowances

        1. 334.Company's pool of field allowances

        2. 335.Carrying part of pool of field allowances into following period

        3. 336.Carrying whole of pool of field allowances into following period

      3. Field allowance: when held and unactivated amount

        1. 337.Licensee to hold field allowance

        2. 338.Holding a field allowance on acquisition of equity share

        3. 339.Unactivated amount of field allowance

      4. No change in equity share: activation of allowance

        1. 340.Introduction to section 341

        2. 341.Activation of field allowance

      5. Change in equity share: activation of allowance

        1. 342.Introduction to sections 343 and 344

        2. 343.Reference periods

        3. 344.Activation of field allowance

      6. Change in equity share: transfer of field allowance

        1. 345.Introduction to sections 346 and 347

        2. 346.Reduction of field allowance if equity disposed of

        3. 347.Acquisition of field allowance if equity acquired

      7. Miscellaneous

        1. 348.Adjustments

        2. 349.Orders

      8. Interpretation

        1. 349A.“Additionally-developed oil field”

        2. 350.“New oil field”

        3. 351.“Authorisation of development of an oil field”

        4. 352.“Qualifying oil field”

        5. 353.“Small oil field”

        6. 354.“Ultra heavy oil field”

        7. 355.“Ultra high pressure/high temperature oil field”

        8. 355A.“Large deep water oil field”

        9. 355B.“Large shallow water gas field”

        10. 355C.“Deep water gas field”

        11. 356.“Total field allowance for a new oil field”

        12. 356A.“Total field allowance for an additionally-developed oil field”

        13. 356AA.Other definitions

        14. 357.Other definitions

    11. CHAPTER 8 Supplementary charge: onshore allowance

      1. Introduction

        1. 356B.Overview

        2. 356BA.“Onshore oil-related activities”

        3. 356BB.The activities

        4. 356BC.“Site”

      2. Onshore allowance

        1. 356C.Generation of onshore allowance

        2. 356CA.Disqualifying conditions for section 356C(4)(b)

        3. 356CAA.Expenditure on acquisition of asset: further disqualifying conditions

        4. 356CB.Expenditure not related to an established site

      3. Reduction of adjusted ring fence profits

        1. 356D.Reduction of adjusted ring fence profits

        2. 356DA.Carrying forward of activated allowance

        3. 356DB.Companies with both field allowances and onshore allowance

      4. Activated and unactivated allowance: basic calculation rules

        1. 356E.Activation of allowance: no change of equity share

        2. 356EA.The closing balance of unactivated allowance for an accounting period

        3. 356EB.Carrying forward of unactivated allowance

      5. Transfer of allowances between sites

        1. 356F.Transfer of allowances between sites

      6. Changes in equity share: activation of allowance

        1. 356G.Introduction to sections 356GA to 356GD

        2. 356GA.Reference periods

        3. 356GB.Activation of allowance: reference periods

        4. 356GC.Carry-forward of unactivated allowance from a reference period

        5. 356GD.Unactivated amounts attributable to a reference period

      7. Transfers of allowance on disposal of equity share

        1. 356H.Introduction to sections 356HA and 356HB

        2. 356HA.Reduction of allowance if equity disposed of

        3. 356HB.Acquisition of allowance if equity acquired

      8. Miscellaneous

        1. 356I.Adjustments

        2. 356IA.Orders

      9. Interpretation

        1. 356IB.“Authorisation of development”: oil fields

        2. 356J.“Authorisation of development”: drilling and extraction sites

        3. 356JA.When capital expenditure is incurred

        4. 356JB.Other definitions

    12. CHAPTER 9 Supplementary charge: cluster area allowance

      1. Introduction

        1. 356JC.Overview

      2. Determination of cluster areas

        1. 356JD.Meaning of “cluster area”

        2. 356JDA.Meaning of “previously authorised oil field”

      3. Meaning of “investment expenditure”

        1. 356JE.Meaning of “investment expenditure”

      4. Cluster area allowance

        1. 356JF.Generation of cluster area allowance

        2. 356JFA.Expenditure on acquisition of asset: disqualifying conditions

      5. Reduction of adjusted ring fence profits

        1. 356JG.Reduction of adjusted ring fence profits

        2. 356JGA.Carrying forward of activated allowance

      6. Activated and unactivated allowance: basic calculation rules

        1. 356JH.Activation of allowance: no change of equity share

        2. 356JHA.The closing balance of unactivated allowance for an accounting period

        3. 356JHB.Carrying forward of unactivated allowance

      7. Changes in equity share: reference periods

        1. 356JI.Reference periods

      8. Changes in equity share: activation of allowance

        1. 356JJ.Activation of allowance: reference periods

        2. 356JJA.Unactivated amounts attributable to a reference period

        3. 356JJB.Carry-forward of unactivated allowance from a reference period

      9. Transfers of allowance on disposal of equity share

        1. 356JK.Disposal of equity share: transfer of allowance

        2. 356JKA.More than one disposal on a single day

        3. 356JKB.Effect of transfer of allowance for transferee

      10. Use of allowance attributable to unlicensed area

        1. 356JL.Use of allowance attributable to unlicensed area

      11. Miscellaneous

        1. 356JM.Adjustments

        2. 356JMA.Regulations amending percentage in section 356JF(2)

      12. Interpretation

        1. 356JN.When capital expenditure is incurred

        2. 356JNA.Licensed sub-areas

        3. 356JNB.Other definitions

  15. PART 8ZA Oil contractors

    1. CHAPTER 1 Introduction

      1. 356K.Overview of Part

    2. CHAPTER 2 Basic definitions

      1. 356L.“Oil contractor activities” etc

      2. 356LA.“Relevant asset”

      3. 356LB.“Associated person”

      4. 356LC.“Lease”

      5. 356LD.“Contractor's ring fence profits”

    3. CHAPTER 3 Deemed separate trade

      1. 356M.Oil contractor activities treated as separate trade

    4. CHAPTER 4 Calculation of profits

      1. Hire of relevant assets

        1. 356N.Restriction on hire etc of relevant assets to be brought into account

        2. 356NA.Restriction on hire: further provision

      2. Loan relationships

        1. 356NB.Restriction on debits to be brought into account

        2. 356NC.Restriction on credits to be brought into account

      3. Relief

        1. 356ND.Management expenses

        2. 356NE.Losses

        3. 356NF.Group relief and group relief for carried-forward losses

        4. 356NG.Capital allowances

      4. Restriction on obtaining certain deductions

        1. 356NH.Restriction on deductions from contractor's ring fence profits

        2. 356NI.Deductions allowances where company has contractor's ring fence profits

        3. 356NJ.Modification of provisions restricting the use of losses

  16. PART 8ZB Transactions in UK land

    1. Introduction

      1. 356OA.Overview of Part

    2. Amounts treated as profits of a trade

      1. 356OB.Disposals of land in the United Kingdom

      2. 356OC.Disposals of land: profits treated as trading profits

      3. 356OD.Disposals of property deriving its value from land in the United Kingdom

      4. 356OE.Disposals within section 356OD: profits treated as trading profits

      5. 356OF.Profits and losses

    3. Person to whom profits attributed

      1. 356OG.The chargeable company

    4. Anti-fragmentation

      1. 356OH.Fragmented activities

    5. Calculation of profit or gain on disposal

      1. 356OI.Calculation of profit or gain on disposal

      2. 356OJ.Apportionments

    6. Arrangements for avoiding tax

      1. 356OK.Arrangements for avoiding tax

    7. Exemption

      1. 356OL.Profits attributable to period before relevant activities etc began

    8. Other supplementary provisions

      1. 356OM.Tracing value

      2. 356ON.Relevance of transactions, arrangements, etc

    9. Interpretation

      1. 356OO.“Another person”

      2. 356OP.“Arrangement”

      3. 356OQ.“Disposal”

      4. 356OR.“Land” and related expressions

      5. 356OS.References to realising a gain

      6. 356OT.Related parties

  17. PART 8A Profits arising from the exploitation of patents etc

    1. CHAPTER 1 Reduced corporation tax rate for profits from patents etc

      1. 357A.Election for special treatment of profits from patents etc

    2. CHAPTER 2 Qualifying companies

      1. 357B.Meaning of “qualifying company”

      2. 357BA.Meaning of “exclusive licence”

      3. 357BB.Rights to which this Part applies

      4. 357BBA.Rights to which this Part applies: EU rights

      5. 357BC.The development condition

      6. 357BD.Meaning of “qualifying development”

      7. 357BE.The active ownership condition

    3. CHAPTER 2A Relevant IP profits: cases mentioned in section 357A(6)

      1. Steps for calculating relevant IP profits of a trade

        1. 357BF.Relevant IP profits

      2. Finance income

        1. 357BG.Finance income

      3. Relevant IP income

        1. 357BH.Relevant IP income

        2. 357BHA.Notional royalty

        3. 357BHB.Excluded income

        4. 357BHC.Mixed sources of income

      4. Excluded debits etc

        1. 357BI.Excluded debits

        2. 357BIA.Certain amounts not to be deducted from sub-streams at Step 4 of section 357BF

      5. Routine return figure

        1. 357BJ.Routine return figure

        2. 357BJA.Routine deductions

        3. 357BJB.Deductions that are not routine deductions

      6. Marketing assets return figure

        1. 357BK.Marketing assets return figure

        2. 357BKA.Notional marketing royalty

        3. 357BKB.Actual marketing royalty

      7. R&D fraction

        1. 357BL.Introduction

        2. 357BLA.The R&D fraction

        3. 357BLB.Qualifying expenditure on relevant R&D undertaken in-house

        4. 357BLC.Qualifying expenditure on relevant R&D sub-contracted to unconnected persons

        5. 357BLD.Qualifying expenditure on relevant R&D sub-contracted to connected persons

        6. 357BLE.Qualifying expenditure on acquisition of relevant qualifying IP rights

        7. 357BLEA.Cases where the company is a party to a CSA

        8. 357BLF.Meaning of the “relevant period” etc

        9. 357BLG.Cases where the company is a new entrant with insufficient information about pre-enactment expenditure

        10. 357BLH.R&D fraction: increase for exceptional circumstances

      8. Profits arising before grant of right

        1. 357BM.Profits arising before grant of right

      9. Small claims treatment

        1. 357BN.Small claims treatment

        2. 357BNA.Notional royalty election

        3. 357BNB.Small claims figure election

        4. 357BNC.Global streaming election

    4. CHAPTER 2B Relevant IP profits: cases mentioned in section 357A(7): income from new IP

      1. 357BO.Relevant IP profits

      2. 357BP.Meaning of “new qualifying IP right” and “old qualifying IP right”

      3. 357BQ.The modifications

    5. CHAPTER 3 Relevant IP profits : cases mentioned in section 357A(7): no income from new IP

      1. Steps for calculating relevant IP profits of a trade

        1. 357C.Relevant IP profits

      2. Total gross income of trade

        1. 357CA.Total gross income of a trade

        2. 357CB.Finance income

      3. Relevant IP income

        1. 357CC.Relevant IP income

        2. 357CD.Notional royalty

        3. 357CE.Excluded income

        4. 357CF.Mixed sources of income

      4. Calculating profits of trade

        1. 357CG.Adjustments in calculating profits of trade

        2. 357CH.Shortfall in R&D expenditure

        3. 357CHA.Shortfall in qualifying expenditure

      5. Routine return figure

        1. 357CI.Routine return figure

        2. 357CJ.Routine deductions

        3. 357CK.Deductions that are not routine deductions

      6. Election for small claims treatment

        1. 357CL.Companies eligible to elect for small claims treatment

        2. 357CM.Small claims amount

      7. Marketing assets return figure

        1. 357CN.Marketing assets return figure

        2. 357CO.Notional marketing royalty

        3. 357CP.Actual marketing royalty

      8. Profits arising before grant of right

        1. 357CQ.Profits arising before grant of right

    6. CHAPTER 4 Streaming

      1. 357D.Alternative method of calculating relevant IP profits: “streaming”

      2. 357DA.Relevant IP profits

      3. 357DB.Method of allocation

      4. 357DC.The mandatory streaming conditions

    7. CHAPTER 5 Relevant IP losses

      1. 357E.Company with relevant IP losses: set-off amount

      2. 357EA.Effect of set-off amount on company with more than one trade

      3. 357EB.Allocation of set-off amount within a group

      4. 357EC.Carry-forward of set-off amount

      5. 357ED.Company ceasing to carry on trade, etc

      6. 357EE.Transfer of a trade between group members

      7. 357EF.Payments between group members in consequence of section 357EB

    8. CHAPTER 6 Anti-avoidance

      1. Licences conferring exclusive rights

        1. 357F.Licences conferring exclusive rights

      2. Incorporation of qualifying items

        1. 357FA.Incorporation of qualifying items

      3. Tax advantage schemes

        1. 357FB.Tax advantage schemes

    9. CHAPTER 7 Supplementary

      1. Elections under section 357A

        1. 357G.Making of election under section 357A(1) or (11)(b)

        2. 357GA.Revocation of election made under section 357A(1)

      2. Partnerships

        1. 357GB.Application of this Part in relation to partnerships

      3. Cost-sharing arrangements

        1. 357GC.Meaning of “cost-sharing arrangement

        2. 357GCZA.Qualifying IP right held by another party to CSA

        3. 357GCZB.Exclusive licence held by another party to CSA

        4. 357GCZC.R&D undertaken or contracted out by another party to CSA

        5. 357GCZD.Acquisition of qualifying IP rights etc by another party to CSA

        6. 357GCZE.Treatment of expenditure in connection with formation of CSA etc

        7. 357GCZF.Treatment of income in connection with formation of CSA etc

      4. Transferred trades

        1. 357GCA.Application of this Part in relation to transferred trades

      5. Interpretation

        1. 357GD.Meaning of “group”

        2. 357GE.Other interpretation

  18. PART 8B Trading profits taxable at the Northern Ireland rate

    1. CHAPTER 1 Introductory

      1. 357H.Introduction

    2. CHAPTER 2 The Northern Ireland rate

      1. 357I.The Northern Ireland rate

      2. 357IA.Power of Northern Ireland Assembly to set Northern Ireland rate

    3. CHAPTER 3 Northern Ireland rate applied to Northern Ireland profits and losses

      1. Introductory

        1. 357J.Introductory

      2. Profits chargeable to corporation tax and rates

        1. 357JA.Profits chargeable to corporation tax and rates

      3. Loss relief in relation to Northern Ireland profits and losses: Chapter 2 of Part 4

        1. 357JB.Availability of relief

        2. 357JC.Restriction on deductions

      4. Loss relief in relation to Northern Ireland profits and losses: section 45

        1. 357JD.Availability of relief

        2. 357JE.Restriction on deductions

      5. Loss relief in relation to Northern Ireland profits and losses: Part 5

        1. 357JF.Availability of relief

        2. 357JG.Restriction on deductions

        3. 357JH.Modifications of Chapter 4 of Part 5

      6. Loss relief in relation to Northern Ireland profits and losses: Part 5A

        1. 357JHA.Availability of relief

        2. 357JHB.Restriction on deductions

        3. 357JHC.Modifications of Chapter 4 of Part 5A

        4. 357JHD.Modifications of Chapter 5 of Part 5A

      7. Transfers of trade without a change of ownership: Chapter 1 of Part 22

        1. 357JI.Transfers of trade without a change of ownership

      8. Restricted deductions

        1. 357JJ.Restricted deduction: Northern Ireland rate lower than main rate

    4. CHAPTER 4 Basic definitions

      1. Application of Chapter

        1. 357K.Application of Chapter

      2. Meaning of “Northern Ireland company”

        1. 357KA.“Northern Ireland company”

      3. Meaning of “qualifying trade”

        1. 357KB.“Qualifying trade”

      4. Meaning of “SME”

        1. 357KC.“SME”

      5. Meaning of “Northern Ireland employer”

        1. 357KD.“Northern Ireland employer”

        2. 357KE.Northern Ireland workforce conditions

      6. Meaning of “disqualified close company”

        1. 357KEA.“Disqualified close company”

    5. CHAPTER 5 Northern Ireland regional establishments

      1. General

        1. 357L.Northern Ireland regional establishments of companies

      2. Circumstances where there is no NIRE

        1. 357LA.Agent of independent status

        2. 357LB.Alternative finance arrangements

      3. Brokers

        1. 357LC.The independent broker condition

      4. Investment managers

        1. 357LD.The independent investment manager conditions

        2. 357LE.Investment managers: the 20% rule

        3. 357LF.Section 357LE: interpretation

        4. 357LG.Application of 20% rule to collective investment schemes

        5. 357LH.Meaning of “investment manager” and “investment transaction”

      5. Lloyd's agents

        1. 357LI.Lloyd's agents

      6. Supplementary

        1. 357LJ.Investment managers: disregard of certain chargeable profits

        2. 357LK.Miscellaneous

    6. CHAPTER 6 Northern Ireland profits and losses etc: SMEs that are Northern Ireland employers

      1. 357M.Introductory

      2. 357MA.Northern Ireland profits or losses and mainstream profits or losses

      3. 357MB.Profit imputed to back-office activities

    7. CHAPTER 7 Northern Ireland profits and losses etc: SMEs that are not Northern Ireland employers and large companies

      1. Introductory

        1. 357N.Introductory

      2. Northern Ireland profits or losses and mainstream profits or losses

        1. 357NA.Northern Ireland profits or losses and mainstream profits or losses

        2. 357NB.Profit imputed to Northern Ireland back-office activities

      3. The separate enterprise principle

        1. 357NC.The separate enterprise principle

        2. 357ND.Transactions treated as being on arm's length terms

        3. 357NE.Provision of goods or services for NIRE

      4. Rules about deductions and receipts

        1. 357NF.Allowable deductions

        2. 357NG.Deductions attributable to the NIRE for costs

        3. 357NH.Payments and receipts in respect of intangible assets

        4. 357NI.Interest or other financing costs and receipts

      5. Supplementary

        1. 357NJ.Losses

        2. 357NK.Trade includes office

    8. CHAPTER 8 Intangible fixed assets

      1. Introductory

        1. 357O.Introductory

      2. Calculating Northern Ireland profits or Northern Ireland losses

        1. 357OA.Rules affecting calculation of Northern Ireland profits or losses

      3. Northern Ireland intangibles credits and Northern Ireland intangibles debits

        1. 357OB.Northern Ireland intangibles credits and debits: SMEs that are Northern Ireland employers

        2. 357OC.Northern Ireland intangibles credits and debits: SMEs that are not Northern Ireland employers and large companies

      4. Realisation credits and realisation debits

        1. 357OD.“Realisation credit” and “realisation debit”

        2. 357OE.The Northern Ireland element of a realisation credit or debit

        3. 357OF.Northern Ireland element: general rule

        4. 357OG.Northern Ireland element: credits where roll-over relief involved

      5. Pre-commencement assets

        1. 357OH.Pre-commencement asset

        2. 357OI.Goodwill

        3. 357OJ.Assets representing production expenditure on films

        4. 357OK.Fungible assets

        5. 357OL.Realisation and acquisition of fungible assets

      6. Assets treated as pre-commencement assets

        1. 357OM.Assets whose value derives from pre-commencement assets

        2. 357ON.The pre-commencement status conditions

        3. 357OO.Assets acquired in connection with disposals of pre-commencement assets

      7. Interpretation

        1. 357OP.Interpretation of Chapter

    9. CHAPTER 9 Research and development expenditure

      1. Introductory

        1. 357P.Introduction and interpretation

      2. Chapter 6A of Part 3 of CTA 2009

        1. 357PA.R&D expenditure credit under Chapter 6A of Part 3 of CTA 2009

      3. Chapter 2 of Part 13 of CTA 2009

        1. 357PB.Additional deduction under section 1044 of CTA 2009

        2. 357PC.Tax credit under section 1054 of CTA 2009: entitlement

        3. 357PD.Tax credit under section 1054 of CTA 2009: amount of tax credit

        4. 357PE.Restriction on losses carried forward where tax credit claimed

      4. Chapter 7 of Part 13 of CTA 2009

        1. 357PF.Additional deduction under section 1087 of CTA 2009

    10. CHAPTER 10 Remediation of contaminated or derelict land

      1. Introductory

        1. 357Q.Introduction and interpretation

      2. Additional deduction under section 1149 of CTA 2009

        1. 357QA.Additional deduction

      3. Tax credit under section 1151 of CTA 2009

        1. 357QB.Tax credit: entitlement

        2. 357QC.Tax credit: amount of tax credit

        3. 357QD.Restriction on losses carried forward where tax credit claimed

    11. Chapter 10A Films, television programmes and video games qualifying for expenditure credit

      1. Introduction

        1. 357QE.Application and interpretation

      2. Expenditure credit

        1. 357QF.Expenditure credit to count towards mainstream profits or losses

      3. Losses of separate trade

        1. 357QG.Carrying forward of production losses

        2. 357QH.Transfer of terminal loss

    12. CHAPTER 11 Film tax relief

      1. Introductory

        1. 357R.Introduction and interpretation

      2. Film tax relief

        1. 357RA.Northern Ireland additional deduction

        2. 357RB.Northern Ireland supplementary deduction

        3. 357RC.Northern Ireland supplementary deduction: amount

        4. 357RD.Film tax credit: Northern Ireland supplementary deduction ignored

        5. 357RE.Artificially inflated claims for additional deduction

      3. Film losses

        1. 357RF.Restriction on use of losses while film is in production

        2. 357RG.Use of losses in later periods

        3. 357RH.Terminal losses

    13. CHAPTER 12 Television production

      1. Introductory

        1. 357S.Introduction and interpretation

      2. Television tax relief

        1. 357SA.Northern Ireland additional deduction

        2. 357SB.Northern Ireland supplementary deduction

        3. 357SC.Northern Ireland supplementary deduction: amount

        4. 357SD.Tax credit: Northern Ireland supplementary deduction ignored

        5. 357SE.Artificially inflated claims for additional deduction

      3. Programme losses

        1. 357SF.Restriction on use of losses while programme in production

        2. 357SG.Use of losses in later periods

        3. 357SH.Terminal losses

    14. CHAPTER 13 Video games development

      1. Introductory

        1. 357T.Introduction and interpretation

      2. Video games tax relief

        1. 357TA.Northern Ireland additional deduction

        2. 357TB.Northern Ireland supplementary deduction

        3. 357TC.Northern Ireland supplementary deduction: amount

        4. 357TD.Tax credit: Northern Ireland supplementary deduction ignored

        5. 357TE.Artificially inflated claims for additional deduction

      3. Video game losses

        1. 357TF.Restriction on use of losses while video game in development

        2. 357TG.Use of losses in later periods

        3. 357TH.Terminal losses

    15. CHAPTER 14 Theatrical productions

      1. Introductory

        1. 357U.Introduction and interpretation

      2. Tax relief for theatrical productions

        1. 357UA.Northern Ireland additional deduction

        2. 357UB.Northern Ireland supplementary deduction

        3. 357UC.Northern Ireland supplementary deduction: amount

        4. 357UD.Tax credit: Northern Ireland supplementary deduction ignored

        5. 357UE.Transactions not entered into for genuine commercial reasons

      3. Use of losses

        1. 357UF.Restriction on use of losses before completion period

        2. 357UG.Use of losses in the completion period

        3. 357UH.Terminal losses

      4. Provisional entitlement to relief

        1. 357UI.Provisional entitlement to relief

    16. CHAPTER 14A Orchestra tax relief

      1. Introductory

        1. 357UJ.Introduction and interpretation

      2. Orchestra tax relief

        1. 357UK.Northern Ireland additional deduction

        2. 357UL.Northern Ireland supplementary deduction

        3. 357UM.Northern Ireland supplementary deduction: amount

        4. 357UN.Orchestra tax credit: Northern Ireland supplementary deduction ignored

      3. Losses of separate orchestral trade

        1. 357UO.Restriction on use of losses before completion period

        2. 357UP.Use of losses in the completion period

        3. 357UQ.Terminal losses

    17. CHAPTER 14B Museums and galleries exhibition tax relief

      1. Introductory

        1. 357UR.Introduction and interpretation

      2. Museums and galleries exhibition tax relief

        1. 357US.Northern Ireland additional deduction

        2. 357UT.Northern Ireland supplementary deduction

        3. 357UU.Northern Ireland supplementary deduction: amount

        4. 357UV.Museums and galleries exhibition tax credit: Northern Ireland supplementary deduction ignored

      3. Losses of separate exhibition trade

        1. 357UW.Restriction on use of losses before completion period

        2. 357UX.Use of losses in the completion period

        3. 357UY.Terminal losses

    18. CHAPTER 15 Profits arising from the exploitation of patents etc

      1. Introductory

        1. 357V.Introductory

      2. Modification of deduction

        1. 357VA.Modification of section 357A

      3. “Relevant Northern Ireland IP profits”

        1. 357VB.Relevant Northern Ireland IP profits: SMEs that are Northern Ireland employers

        2. 357VC.Relevant Northern Ireland IP profits: SMEs that are not Northern Ireland employers and large companies

      4. Relevant IP losses

        1. 357VD.Relevant IP losses

      5. Interpretation

        1. 357VE.Interpretation of Chapter

    19. CHAPTER 16 Northern Ireland profits and losses etc: partnerships

      1. 357W.Introductory

      2. 357WA.Meaning of “Northern Ireland firm”

      3. 357WB.Meaning of “qualifying partnership trade”

      4. 357WBA.Northern Ireland workforce partnership conditions

      5. 357WBB.Section 357WBA: supplementary

      6. 357WBC.“Disqualified firm”

      7. 357WC.Northern Ireland profits etc of firm determined under Chapter 6

      8. 357WD.Northern Ireland profits etc of firm determined under Chapter 7

      9. 357WE.Sections 357WC and 357WD: interpretation

      10. 357WF.Application of section 747 of CTA 2009 to Northern Ireland firm

      11. 357WG.Application of Part 8A to Northern Ireland firm

      12. 357WH.Allocation of Northern Ireland profits etc of firm to company

    20. CHAPTER 17 Excluded trades, excluded activities and back-office activities

      1. Introductory

        1. 357X.Introduction

      2. Excluded trades

        1. 357XA.Oil activities

        2. 357XB.Lending and investment

        3. 357XC.Investment management

        4. 357XD.Insurance: long-term business

        5. 357XE.Re-insurance trade

      3. Excluded activities

        1. 357XF.Re-insurance activity

        2. 357XG.Exploration and exploitation of UK sector of continental shelf

      4. Powers

        1. 357XH.Power to amend definition of “excluded trade” or “excluded activity”

        2. 357XI.Power to make provision about meaning of “back-office activities”

  19. PART 8C Restitution interest

    1. CHAPTER 1 Amounts taxed as restitution interest

      1. 357YA.Charge to corporation tax on restitution interest

      2. 357YB.Restitution interest chargeable as income

      3. 357YC.Meaning of “restitution interest”

      4. 357YD.Further provision about amounts included, or not included, in “restitution interest”

      5. 357YDA.Life insurance companies: amounts representing policyholder income

      6. 357YE.Period in which amounts are to be brought into account

      7. 357YF.Companies without GAAP-compliant accounts

      8. 357YG.Restitution interest: appeals made out of time

      9. 357YH.Countering effect of avoidance arrangements

      10. 357YI.Interpretation of section 357YH

      11. 357YJ.Examples of results that may indicate exclusion not applicable

    2. CHAPTER 2 Application of restitution payments rate

      1. 357YK.Corporation tax rate on restitution interest

      2. 357YL.Exclusion of reliefs, set-offs etc

    3. CHAPTER 3 Migration, transfers of rights etc

      1. 357YM.Assignment of rights to person not chargeable to corporation tax

      2. 357YN.Migration of company with claim to restitution interest

      3. 357YNA.Transfer of rights: restitution interest arising after a winding up or dissolution

      4. 357YNB.Meaning of “related company”

    4. CHAPTER 4 Payment and collection of tax on restitution interest

      1. 357YO.Duty to deduct tax from payments of restitution interest

      2. 357YP.Treatment of amounts deducted under section 357YO

      3. 357YQ.Assessment of tax chargeable on restitution interest

      4. 357YR.Interest on excessive amounts withheld

      5. 357YS.Appeal against deduction

      6. 357YT.Amounts taxed at restitution payments rate to be outside instalment payments regime

    5. CHAPTER 5 Supplementary provisions

      1. 357YU.Interpretation

      2. 357YV.Relationship of Part with other corporation tax provisions

      3. 357YW.Power to amend

  20. Part 9 Leasing plant or machinery

    1. Chapter 1 Introduction

      1. 358.Introduction to Part

    2. Chapter 2 Long funding leases of plant or machinery

      1. Introduction

        1. 359.Overview of Chapter

      2. Lessors under long funding finance leases

        1. 360.Lessor under long funding finance lease: rental earnings

        2. 361.Lessor under long funding finance lease: exceptional items

        3. 362.Lessor under long funding finance lease making termination payment

      3. Lessors under long funding operating leases

        1. 363.Lessor under long funding operating lease: periodic deduction

        2. 364.“Starting value”: general

        3. 365.“Starting value” where plant or machinery originally unqualifying

        4. 366.Long funding operating lease: lessor's additional expenditure

        5. 367.Determination of remaining residual value resulting from lessor's first additional expenditure

        6. 368.Determination of remaining residual value resulting from lessor's further additional expenditure

        7. 369.Lessor under long funding operating lease: termination of lease

      4. Cases where sections 360 to 369 do not apply

        1. 370.Plant or machinery held as trading stock

        2. 371.Adjustments where sections 360 to 369 subsequently disapplied by section 370

        3. 372.Lessor also lessee under non-long funding lease

        4. 373.Other avoidance

        5. 374.Provision supplementing section 373

        6. 375.Adjustments where sections 360 to 369 subsequently disapplied by section 373

        7. 376.Films

      5. Lessees under long funding finance leases

        1. 377.Lessee under long funding finance lease: limit on deductions

        2. 377A.Lessee under long funding finance leases: right-of-use leases

        3. 378.Lessee under long funding finance lease: termination

      6. Lessees under long funding operating leases

        1. 379.Lessee under long funding operating lease

        2. 380.“Starting value” in section 379

      7. Interpretation

        1. 381.Interpretation of Chapter

    3. Chapter 3 Sales of lessors: leasing business carried on by a company alone

      1. Introduction

        1. 382.Introduction to Chapter

      2. Income and matching expense in different accounting periods

        1. 383.Income and matching expense in different accounting periods

        2. 384.Amount of income and expense

        3. 385.No carry back of loss against the income

        4. 386.Relief for expense otherwise giving rise to carried forward loss

      3. “Business of leasing plant or machinery”

        1. 387.“Business of leasing plant or machinery”

        2. 388.“Relevant plant or machinery value” for condition A in section 387

        3. 389.Provision supplementing section 388

        4. 390.Relevant plant or machinery value where relevant company lessee under long funding lease etc

        5. 391.Relevant company's income for condition B in section 387

      4. “Relevant change in relationship”

        1. 392.“Relevant change in relationship”

        2. 393.Qualifying 75% subsidiaries

        3. 394.Consortium relationships

        4. 394ZA.Company joining tonnage tax group

      5. “Qualifying change of ownership”

        1. 394A.“Qualifying change of ownership”

        2. 395.No qualifying change of ownership in certain intra-group reorganisations

        3. 396.No qualifying change of ownership where principal company's interest in consortium company unchanged

        4. 397.Companies owned by consortiums and members of consortiums

        5. 398. “Qualifying 75% ... subsidiary” etc

      6. Election out of qualifying change of ownership

        1. 398A.Election out of qualifying change of ownership

        2. 398B.The election

        3. 398C.Special treatment of A's trade or business that includes leasing

        4. 398D. Restrictions on use of losses etc

        5. 398E.Restriction on artificial losses or reductions in profits

        6. 398F.Limit on availability of capital allowances to A

        7. 398G.Transfers into and out of A

      7. The amount of the income

        1. 399.The amount of the income: the basic amount

        2. 400.“PM” in section 399

        3. 401.Provisions supplementing section 400

        4. 402. “PM” where relevant company lessee under long funding lease etc

        5. 403.“TWDV” in section 399

        6. 404.Amount to be nil if basic amount negative

        7. 405.Adjustment to the basic amount: qualifying 75% subsidiaries

        8. 406.Adjustment to the basic amount: consortium relationships

        9. 407.Migration

      8. “Associated company”

        1. 408.“Associated company”

    4. Chapter 4 Sales of lessors: leasing business carried on by a company in partnership

      1. Introduction

        1. 409.Introduction to Chapter

      2. “Business of leasing plant or machinery”

        1. 410.“Business of leasing plant or machinery”

        2. 411.“Relevant plant or machinery value” for condition A in section 410

        3. 412.Provision supplementing section 411

        4. 413.Relevant plant or machinery value where partnership lessee under long funding lease etc

        5. 414.Partnership's income for condition B in section 410

      3. “Qualifying change” in company's interest in a business

        1. 415.“Qualifying change” in company's interest in a business

        2. 416.Determining the percentage share in the profits or loss of business

      4. Qualifying changes in partner company's interest in business

        1. 417.Partner company's income and other companies' matching expense

        2. 418.Amount of income and expense

        3. 419.Relief for expense otherwise giving rise to carried forward loss

        4. 420.Exception: companies carrying on business ceasing to share in its profits

        5. 421.The amount of the income: the basic amount

        6. 422.Amount to be nil if basic amount negative

        7. 423.Adjustment to the basic amount

        8. 424.The amount of expense

      5. Qualifying changes of ownership in relation to partner company

        1. 425.Partner company's income and matching expense in different accounting periods

        2. 426.Amount of income and expense

        3. 427.No carry back of loss against the income

        4. 428.Relief for expense otherwise giving rise to carried forward loss

        5. 429.The amount of the income

      6. Interpretation

        1. 430.“Associated company”

        2. 431.“Profits” and “loss”

    5. Chapter 5 Sales of lessors: anti-avoidance provisions

      1. 432.Restrictions on relief for Chapter 3 or 4 expenses: introduction

      2. 433.Restrictions applying to the restricted loss amount

      3. 433A.Restrictions not applying to the restricted loss amount

      4. 434.Introduction to sections 435 and 436

      5. 435.Disregard of increases and decreases in certain amounts

      6. 436.Balance sheet amounts determined on assumption company has no liabilities

    6. Chapter 6 Sales of lessors: general interpretation

      1. 437.Interpretation of the sales of lessors Chapters

      2. 437A.Determining the ascribed value of plant or machinery

      3. 437B.Section 437A: supplementary

      4. 437C.Present value of a lease

  21. Part 10 Close companies

    1. Chapter 1 Overview of Part

      1. 438.Overview of Part

    2. Chapter 2 Basic definitions

      1. Meaning of “close company": general

        1. 439.“Close company”

        2. 440.Basis of winding up under section 439(3)

        3. 441.Treatment of some persons as participators or directors for the purposes of section 439(3)

      2. Companies which are not to be close companies

        1. 442.Particular types of company

        2. 443.Companies controlled by or on behalf of Crown

        3. 444.Companies involved with non-close companies

        4. 445.Section 444: registered pension schemes

        5. 446.Particular types of quoted company

        6. 447.Section 446: meaning of “shares beneficially held by the public” etc

      3. Meaning of other expressions in this Part

        1. 448.“Associate”

        2. 449.“Associated company”

        3. 450.“Control”

        4. 451.Section 450: rights to be attributed etc

        5. 452.“Director”

        6. 453.“Loan creditor”

        7. 454.“Participator”

    3. Chapter 3 Charge to tax in case of loan to participator

      1. Charge to tax in case of loan to participator

        1. 455.Charge to tax in case of loan to participator

      2. Exceptions to the charge to tax under section 455

        1. 456.Exceptions to the charge under section 455

        2. 457.Section 456: meaning of “material interest in a company”

      3. Relief in case of repayment or release of loan

        1. 458.Relief in case of repayment or release of loan

      4. Loan treated as made to participator

        1. 459.Loan treated as made to participator

      5. Loan treated as made by close company

        1. 460.Loan treated as made by close company

        2. 461.Exception to section 460

        3. 462.Determination of particular questions as a result of section 460

      6. Taxation of debtor on release of loan to trustees of settlement which has ended

        1. 463.Taxation of debtor on release of loan to trustees of settlement which has ended

        2. 464.Section 463: other person treated as releasing or writing off debt

    4. CHAPTER 3A Charge to tax: other arrangements

      1. 464A.Charge to tax: arrangements conferring benefit on participator

      2. 464B.Relief in case of return payment to company

    5. CHAPTER 3B Repayments and return payments

      1. 464C.Treatment of certain repayments and return payments

      2. 464D.Section 464C: supplementary

    6. Chapter 4 Power to obtain information

      1. 465.Power to obtain information

  22. Part 11 Charitable companies etc

    1. Chapter 1 Introduction

      1. 466.Overview of Part

      2. 467.Meaning of “charitable company”

      3. 468.Meaning of “eligible body”

      4. 469.Conditions for qualifying as a scientific research association

      5. 470.Meaning of “research and development” in section 469

    2. Chapter 2 Gifts and other payments

      1. Gifts and other payments to charitable companies

        1. 471.Gifts qualifying for gift aid relief: income tax treated as paid

        2. 472.Gifts qualifying for gift aid relief: corporation tax liability and exemption

        3. 472A.Gifts under payroll deduction schemes: corporation tax liability and exemption

        4. 473.Gifts of money from companies: corporation tax liability and exemption

        5. 474.Payments from other charities: corporation tax liability and exemption

      2. Gifts to eligible bodies

        1. 475.Gifts qualifying for gift aid relief: income tax treated as paid and exemption

        2. 476.Gifts of money from companies: exemption

      3. Gifts to scientific research associations

        1. 477.Gifts of money from companies: exemption

      4. Claims

        1. 477A.Claims in relation to gift aid relief

    3. Chapter 3 Other exemptions

      1. Exemptions

        1. 478.Exemption for profits etc of charitable trades

        2. 479.Meaning of “charitable trade”

        3. 480.Exemption for profits of small-scale trades

        4. 481.Exemption from charges under provisions to which section 1173 applies

        5. 482.Condition as to trading and miscellaneous incoming resources

        6. 483.Exemption for profits from fund-raising events

        7. 484.Exemption for profits from lotteries

        8. 485.Exemption for property income etc

        9. 486.Exemption for investment income and non-trading profits from loan relationships

        10. 487.Exemption for public revenue dividends

        11. 488.Exemption for certain miscellaneous income

        12. 489.Exemption for income from estates in administration

      2. Application of exemptions to certain bodies

        1. 490.Eligible bodies

        2. 491.Scientific research associations

      3. Claims

        1. 491A.Claims in relation to certain reliefs

    4. Chapter 4 Restrictions on exemptions

      1. Restrictions on exemptions

        1. 492.Restrictions on exemptions

        2. 493.The non-exempt amount

        3. 494.Attributing income to the non-exempt amount

        4. 495.How income is attributed to the non-exempt amount

      2. Non-charitable expenditure

        1. 496.Meaning of “non-charitable expenditure”

        2. 497.Section 496: supplementary

        3. 498.Section 496(1)(d): meaning of expenditure

        4. 499.Section 496(1)(d): accounting period in which certain expenditure treated as incurred

        5. 500.Section 496(1)(d): payment to body outside the UK

        6. 501.Section 496(1)(g) and (h): investments and loans

      3. Substantial donor transactions

        1. 502.Transactions with substantial donors

        2. 503.Meaning of “relievable gift”

        3. 504.Non-charitable expenditure in substantial donor transactions

        4. 505.Adjustment if section 504(1) and (2) applied to single transaction

        5. 506.Section 504: certain payments and benefits to be ignored

        6. 507.Transactions: exceptions

        7. 508.Donors: exceptions

        8. 509.Connected charities

        9. 510.Substantial donor transactions: supplementary

      4. Approved charitable investments and loans

        1. 511.Approved charitable investments

        2. 512.Securities which are approved charitable investments

        3. 513.Conditions to be met for some securities

        4. 514.Approved charitable loans

      5. Carry back of excess non-charitable expenditure

        1. 515.Excess expenditure treated as non-charitable expenditure of earlier periods

        2. 516.Rules for attributing excess expenditure to earlier periods

        3. 517.Adjustments in consequence of section 515

  23. Part 12 Real Estate Investment Trusts

    1. Chapter 1 Introduction

      1. Introductory

        1. 518.Introduction to Part

      2. Key concepts

        1. 519.“Property rental business”

        2. 520.“UK property rental business” of non-UK companies

        3. 521.“UK company” and “non-UK company”

        4. 522.“Residual business”

    2. Chapter 2 Requirements for being a UK REIT

      1. Becoming a UK REIT

        1. 523.Notice for a group of companies to become a UK REIT

        2. 524.Notice for a company to become a UK REIT

        3. 525.Notice under section 523 or 524: supplementary

        4. 526.Duration of status as UK REIT

      2. Being a UK REIT in relation to an accounting period

        1. 527.Being a UK REIT in relation to an accounting period

        2. 528.Conditions for company

        3. 528ZA.Listing requirement: ownership by institutional investors

        4. 528ZB.Genuine diversity of ownership condition

        5. 528A.Further condition relating to shares

        6. 528B.Relaxation of section 528A condition for accounting periods 1 to 3

        7. 529.Conditions as to property rental business

        8. 530.Condition as to distribution of profits

        9. 530A.Condition as to distribution of profits: increase in profits after delivery of tax return

        10. 531.Conditions as to balance of business

        11. 532.Financial statements for group UK REITs

        12. 533.Financial statements: supplementary

    3. Chapter 3 Tax treatment of profits and gains of UK REITs

      1. 534.Profits

      2. 535.Gains

      3. 535A.Gains: disposals of rights or interests in UK property rich companies

      4. 535B.Section 535A: use of pre-April 2019 residual business losses or deficits

    4. Chapter 4 Entering the UK REIT regime

      1. 536.Effects of entry: corporation tax

      2. 537.Effects of entry: CAA 2001

      3. 538.Entry charge

      4. 539.Calculation of the notional amount

      5. 540.Election to treat notional income as arising in instalments

    5. Chapter 5 Assets etc

      1. Ring-fencing of property rental business

        1. 541.Ring-fencing of property rental business

        2. 542.Disapplication of certain provisions

      2. Profits: financing-cost ratio

        1. 543.Profit: financing-cost ratio

        2. 544.Meaning of “property profits” and “property financing costs”

      3. Cancellation of tax advantage

        1. 545.Cancellation of tax advantage

        2. 546.Appeal against notice under section 545

      4. Funds awaiting reinvestment

        1. 547.Funds awaiting reinvestment

    6. Chapter 6 Distributions

      1. Recipients of distributions

        1. 548.Distributions: liability to tax

        2. 549.Distributions: supplementary

        3. 549A.Distributions from one UK REIT to another UK REIT

      2. Attribution of distributions

        1. 550.Attribution of distributions

      3. Distributions to certain shareholders

        1. 551.Tax consequences of distribution to holder of excessive rights

        2. 552.“The section 552 amount”

        3. 553.Meaning of “holder of excessive rights” and “excluded holder”

        4. 554.Regulations: distributions to holders of excessive rights

        5. 554A. Meaning of “distribution”

    7. Chapter 7 Gains etc

      1. Movement of assets

        1. 555.Assets: change of use

        2. 556.Disposal of assets

        3. 557.Movement of assets into ring fence

      2. Demergers

        1. 558.Demergers: disposal of asset

        2. 559.Demergers: company leaving group UK REIT

      3. Interpretation

        1. 560.Interpretation of Chapter

    8. Chapter 8 Breach of conditions in Chapter 2

      1. 561.Notice of breach of relevant Chapter 2 condition

      2. 562.Breach of condition C in section 528 (conditions for company)

      3. 562A.Breach of condition D in section 528 (conditions for company)

      4. 562B.Breach of further condition relating to shares

      5. 562C.Breach of further condition relating to shares in accounting periods 1, 2 and 3

      6. 563.Breach of property rental business condition

      7. 564.Breach of condition as to distribution of profits

      8. 565.“The section 565 amount”

      9. 566.Breach of condition B in section 531 in accounting period 1

      10. 567.Meaning of “the notional amount”

      11. 568.Breach of balance of business conditions after accounting period 1

      12. 569.Chapter subject to section 572

    9. Chapter 9 Leaving the UK REIT regime

      1. Introduction

        1. 570.Overview of Chapter

      2. Notice to leave regime

        1. 571.Termination by notice: group or company

        2. 572.Termination by notice: officer of Revenue and Customs

        3. 573.Notice under section 572: tax advantage

        4. 573A.Notice under section 572: condition D in section 528 not met

        5. 573B.Notice under section 572: further condition relating to shares not met

        6. 574.Notice under section 572: serious breach

        7. 575.Notice under section 572: breach of conditions as to property rental business

        8. 576.Notice under section 572: breach of conditions as to balance of business

        9. 577.Notice under section 572: multiple breaches of conditions in Chapter 2

      3. Automatic termination

        1. 578.Automatic termination for breach of certain conditions in section 528

      4. Effects of cessation

        1. 579.Effects of cessation: corporation tax

        2. 580.Effects of cessation: CAA 2001

      5. Early exit

        1. 581.Early exit by notice

        2. 582.Early exit

    10. Chapter 10 Joint ventures

      1. Introduction

        1. 583.Overview of Chapter

        2. 584.Meaning of “joint venture company” and “joint venture group”

        3. 585.Meaning of “venturing group” and “venturing company”

      2. Notice for Part to apply to joint venture

        1. 586.Notice for Part to apply: joint venture company

        2. 587.Notice for Part to apply: joint venture group

      3. Effect and duration of notice

        1. 588.Effect of notice under section 586

        2. 589.Effect of notice under section 587

        3. 590.Duration of notice under section 586 or 587

      4. Specific requirements and modifications

        1. 591.Conditions as to balance of business

        2. 592.Joint venture groups: financial statements

        3. 593.Financial statements under section 532: joint venture groups

        4. 594.Modifications of Chapter 3

      5. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

        1. 595.Joint venture company liable for additional charge

        2. 596.Member of joint venture group liable for additional charge

        3. 597.Cases where no additional charge due

      6. Supplementary

        1. 598.Chapter 10: supplementary

    11. Chapter 11 Part 12: supplementary

      1. Miscellaneous

        1. 599.Calculation of profits

        2. 599A. Amount of distribution consisting of share capital issued in lieu of cash dividend

        3. 600.Power to make regulations about cases involving related persons

        4. 601.Availability of group reliefs

        5. 602.Effect of deemed disposal and reacquisition

        6. 603.Regulations

      2. Interpretation

        1. 604.Property rental business: exclusion of listed business

        2. 605.Property rental business: exclusion of business producing listed income

        3. 606.Groups

        4. 607.Meaning of “entry” and “cessation” etc

        5. 608.References to assets

        6. 609.Definitions

  24. Part 13 Other special types of company etc

    1. Chapter 1 Corporate beneficiaries under trusts

      1. Discretionary payments

        1. 610.Discretionary payments by trustees to companies

      2. Trustees' expenses

        1. 611.Income tax provisions to apply in relation to trustees' expenses

    2. Chapter 2 Authorised investment funds

      1. Introduction

        1. 612.Overview of Chapter

      2. Open-ended investment companies

        1. 613.Meaning of “open-ended investment company”

        2. 614.Applicable corporation tax rate

        3. 615.Umbrella companies

      3. Authorised unit trusts

        1. 616.Meaning of “authorised unit trust” and “unit holder”

        2. 617.Authorised unit trust treated as UK resident company

        3. 618.Applicable corporation tax rate

        4. 619.Umbrella schemes

      4. Court investment funds

        1. 620.Court investment funds

    3. Chapter 3 Unauthorised unit trusts

      1. 621.Treatment of income

      2. 622.Treatment of capital expenditure

    4. CHAPTER 3A Investment trusts

      1. 622A.Power to make provision about treatment of transactions

    5. Chapter 4 Securitisation companies

      1. 623.Meaning of “securitisation company”

      2. 624.Power to make regulations about the taxation of securitisation companies

      3. 625.Regulations: supplementary

    6. Chapter 5 Companies in liquidation or administration

      1. Introduction

        1. 626.Meaning of “final year”, “penultimate year” etc

        2. 627.Meaning of “main rate of corporation tax” for companies with ring fence profits or small profits

      2. Companies in liquidation

        1. 628.Company in liquidation: corporation tax rates

        2. 629.Company in liquidation: making of assessment to tax

      3. Companies in administration

        1. 630.Company in administration: corporation tax rates

        2. 631.Company in administration: making of assessment to tax

      4. Supplementary

        1. 632.Meaning of rate being “fixed” or “proposed”

        2. 633.Exemption for interest on overpaid tax in final accounting period

    7. Chapter 6 Banks etc in compulsory liquidation

      1. 634.Overview of Chapter

      2. 635.Application of Chapter

      3. 636.Charge to corporation tax on winding up receipts

      4. 637.Transfer of rights to payment

      5. 638.Allowable deductions

      6. 639.Election to carry back

      7. 640.Relationship of Chapter with other corporation tax provisions

      8. 641.Interpretation of Chapter

    8. Chapter 7 Co-operative housing associations

      1. 642.Disregard of rent from members and of interest payable

      2. 643.Exemption for gains on a sale of property

      3. 644.Approval of housing associations

      4. 645.Tests to be satisfied by the association

      5. 646.Delegation of powers to the Regulator of Social Housing

      6. 647.Claims under section 642 or 643

      7. 648.Adjustments of liability

      8. 649.Power to make further provision

    9. Chapter 8 Self-build societies

      1. 650.Meaning of “self-build society”

      2. 651.Disregard of rent from members

      3. 652.Exemption for gains on disposals of land to members

      4. 653.Approval of self-build societies

      5. 654.Delegation of powers to the Regulator of Social Housing

      6. 655.Claims under section 651 or 652

      7. 656.Adjustments of liability

      8. 657.Power to make further provision

    10. Chapter 9 Community amateur sports clubs

      1. Basic concepts

        1. 658.Meaning of “community amateur sports club” and “registered club”

        2. 659.Meaning of “open to the whole community”

        3. 660.Meaning of “organised on an amateur basis”

        4. 660A.Clubs consisting mainly of social members

        5. 661.Meaning of “eligible sport”, “qualifying purposes” etc

        6. 661A.The location condition

        7. 661B.The management condition

        8. 661C.Periods over which management condition treated as met

        9. 661CA.The income condition

      2. Gifts ...

        1. 661D.Tax treatment of gifts qualifying for gift aid relief

        2. 661E.Tax treatment of gifts of money from companies

      3. Exemptions

        1. 662.Exemption for UK trading income

        2. 663.Exemption for UK property income

        3. 664.Exemption for interest , gift aid and company gift income

        4. 665.Exemption for chargeable gains

      4. Claims

        1. 665A.Claims in relation to interest , gift aid and company gift income

      5. Restrictions on exemptions

        1. 666.Exemptions reduced if non-qualifying expenditure incurred

        2. 667.Rules for attributing surplus amount to earlier periods etc

        3. 668.How income and gains are attributed

      6. Deemed disposal and acquisition of asset

        1. 669.Asset ceasing to be held for qualifying purposes etc

      7. Decisions and appeals

        1. 670.Notification of HMRC decision

        2. 671.Appeals

  25. Part 14 Change in company ownership

    1. Chapter 1 Introduction

      1. 672.Overview of Part

    2. Chapter 2 Disallowance of trading losses

      1. 673.Introduction to Chapter

      2. 674.Disallowance of trading losses

      3. 674A.Section 674: exception for certain losses of ring fence trade

      4. 675.Disallowance of trading losses: calculation of balancing charges

      5. 676.Company reconstructions

    3. CHAPTER 2A Post-1 April 2017 losses: Further cases involving a change in the company's activities

      1. 676AA.Introduction to Chapter

      2. 676AB.Priority of provisions of Chapters 2 and 3 over this Chapter

      3. 676AC.“Major change in the business” of a company

      4. 676AD.Notional split of accounting period in which change in ownership occurs

      5. 676AE.“Affected profits”

      6. 676AF.Restriction on use of carried-forward post-1 April 2017 trade losses

      7. 676AG.Restriction on debits to be brought into account

      8. 676AH.Restriction on the carry forward of post-1 April 2017 non-trading deficit from loan relationships

      9. 676AI.Restriction on relief for post-1 April 2017 non-trading loss on intangible fixed assets

      10. 676AJ.Restriction on deduction of post-1 April 2017 expenses of management

      11. 676AK.Restriction on use of post-1 April 2017 UK property business losses

      12. 676AL.“Co-transferred company” and “related company”

    4. CHAPTER 2B Asset transferred within group: restriction of relief for post-1 April trade losses

      1. 676BA.Introduction to Chapter

      2. 676BB.Notional split of accounting period in which change in ownership occurs

      3. 676BC.Disallowance of relief for trade losses

      4. 676BD.Meaning of “the relevant provisions”

      5. 676BE.Meaning of “amount of profits which represents a relevant gain”

    5. CHAPTER 2C Disallowance of group relief for carried-forward losses: general provision

      1. 676CA.Introduction to Chapter

      2. 676CB.Restriction on surrender of carried-forward losses

      3. 676CC.Cases where consortium condition 1 or 2 was previously met

      4. 676CD.Cases where consortium condition 3 or 4 was previously met

      5. 676CE.Exceptions to restrictions

      6. 676CF.Cases where Chapter 2, 2A or 3 also applies

      7. 676CG.“Affected profits”

      8. 676CH.“Relevant pre-acquisition loss”

      9. 676CI.Interpretation of Chapter

    6. CHAPTER 2D Asset transferred within group: Restriction of group relief for carried-forward losses

      1. 676DA.Introduction to Chapter

      2. 676DB.Notional split of accounting period in which change in ownership occurs

      3. 676DC.Disallowance of group relief for carried-forward losses

      4. 676DD.Meaning of “the relevant provisions”

      5. 676DE.Meaning of “amount of profits which represents a relevant gain”

    7. CHAPTER 2E Post-1 April 2017 trade losses: cases involving the transfer of a trade

      1. 676EA.Introduction to Chapter

      2. 676EB.Restriction on use of trade losses carried-forward on transfer of trade

      3. 676EC.Restriction on surrender of trade losses carried forward on transfer of trade

      4. 676ED.Indirect transfers of a trade

      5. 676EE.Interpretation of Chapter

    8. Chapter 3 Company with investment business: restrictions on relief: general provision

      1. Introduction

        1. 677.Introduction to Chapter

      2. Notional split of accounting period in which change in ownership occurs

        1. 678.Notional split of accounting period in which change in ownership occurs

      3. Restrictions on relief

        1. 679.Restriction on debits to be brought into account

        2. 680.Restriction on the carry forward of non-trading deficit from loan relationships

        3. 681.Restriction on relief for non-trading loss on intangible fixed assets

        4. 682.Restriction on the deduction of expenses of management

        5. 683.Disallowance of UK property business losses

        6. 684.Disallowance of overseas property business losses

      4. Apportionment of amounts

        1. 685.Apportionment of amounts

        2. 686.Meaning of certain expressions in section 685

      5. Adjustment to balancing charges if relief is restricted

        1. 687.Adjustment to balancing charges if relief is restricted

      6. Meaning of “significant increase in the amount of a company's capital”

        1. 688.Meaning of “significant increase in the amount of a company's capital”

        2. 689.Amount A

        3. 690.Amount B

        4. 691.Meaning of “amount of capital”

    9. Chapter 4 Company with investment business: restrictions on relief: asset transferred within group

      1. Introduction

        1. 692.Introduction to Chapter

        2. 693.Meaning of “amount of profits which represents a relevant gain”

        3. 694.Meaning of “the relevant provisions”

      2. Notional split of accounting period in which change in ownership occurs

        1. 695.Notional split of accounting period in which change in ownership occurs

      3. Restrictions on relief

        1. 696.Restriction on debits to be brought into account

        2. 697.Restriction on the carry forward of non-trading deficit from loan relationships

        3. 698.Restriction on relief for non-trading loss on intangible fixed assets

        4. 699.Restrictions on the deduction of expenses of management

        5. 700.Disallowance of UK property business losses

        6. 701.Disallowance of overseas property business losses

      4. Apportionment of amounts

        1. 702.Apportionment of amounts

        2. 703.Meaning of certain expressions in section 702

    10. Chapter 5 Company without investment business: disallowance of property losses

      1. 704.Company carrying on UK property business

      2. 705.Company carrying on overseas property business

    11. CHAPTER 5A Shell companies: restrictions on relief

      1. Introduction

        1. 705A.Introduction to Chapter

        2. 705B.Notional split of accounting period in which change in ownership occurs

      2. Restrictions on relief

        1. 705C.Restriction on debits to be brought into account

        2. 705D.Restriction on carry forward of non-trading deficit from loan relationships

        3. 705E.Restriction on relief for non-trading loss on intangible fixed assets

      3. Apportionment of amounts

        1. 705F.Apportionment of amounts

        2. 705G.Meaning of certain expressions in section 705F

    12. Chapter 6 Recovery of unpaid corporation tax

      1. General definitions

        1. 706.Meaning of “linked” person

        2. 707.Meaning of “control”

        3. 708.Rights to be attributed for the purposes of section 707

        4. 709.Meaning of “the relevant period”

      2. Recovery of unpaid corporation tax for accounting period beginning before change

        1. 710.Recovery of unpaid corporation tax for accounting period beginning before change

        2. 711.Conditions relating to company's trade or business

        3. 712.Meaning of “a major change in the nature or conduct of a trade or business”

      3. Recovery of unpaid corporation tax for accounting period ending on or after change

        1. 713.Recovery of unpaid corporation tax for accounting period ending on or after change

        2. 714.The expectation condition

        3. 715.Meaning of “transaction entered into in connection with change in ownership”

      4. Miscellaneous

        1. 716.Interest

        2. 717.Effect of payment in pursuance of assessment under section 710 or 713

        3. 718.Meaning of “associated company”

    13. Chapter 7 Meaning of “change in the ownership of a company”

      1. Meaning of “change in the ownership of a company”

        1. 719.Meaning of “change in the ownership of a company”

        2. 720.Section 719: supplementary

        3. 721.When things other than ordinary share capital may be taken into account: Chapters 2 to 5A

        4. 722.When things other than ordinary share capital may be taken into account: Chapter 6

      2. Changes in indirect ownership

        1. 723.Changes in indirect ownership

      3. Disregard of change in ownership

        1. 724.Disregard of change in company ownership

        2. 724A.Disregard of change in parent company

      4. Supplementary provision

        1. 725.Provision applying for the purposes of Chapters 2 to 5A

        2. 726.Interpretation of Chapter

    14. Chapter 8 Supplementary provision

      1. 727.Extended time limit for assessment

      2. 728.Provision of information about ownership of shares etc

      3. 729.Meaning of “company with investment business”

      4. 730.Meaning of “relevant non-trading debit”

  26. PART 14A Transfer of deductions

    1. 730A.Overview

    2. 730B.Interpretation of Part

    3. 730C.Disallowance of deductible amounts: relevant claims

    4. 730D.Disallowance of deductible amounts: profit transfers

  27. PART 14B Tax avoidance involving carried-forward losses

    1. 730E.Overview

    2. 730F.Meaning of “relevant carried-forward loss”

    3. 730G.Disallowance of deductions for relevant carried-forward losses

    4. 730H.Interpretation of section 730G

  28. Part 15 Transactions in securities

    1. Introduction

      1. 731.Overview of Part

      2. 732.Meaning of “corporation tax advantage”

    2. Company liable to counteraction of corporation tax advantage

      1. 733.Company liable to counteraction of corporation tax advantage

      2. 734.Exception where no tax avoidance object shown

    3. Circumstances in which corporation tax advantages obtained or obtainable

      1. 735.Abnormal dividends used for exemptions or reliefs (circumstance A)

      2. 736.Receipt of consideration representing company's assets, future receipts or trading stock (circumstance C)

      3. 737.Receipt of consideration in connection with relevant company distribution (circumstance D)

      4. 738.Receipt of assets of relevant company (circumstance E)

      5. 739.Meaning of “relevant company” in sections 737 and 738

      6. 740.Abnormal dividends: general

      7. 741.Abnormal dividends: the excessive return condition

      8. 742.Abnormal dividends: the excessive accrual condition

    4. Procedure for counteraction of corporation tax advantages

      1. 743.Preliminary notification that section 733 may apply

      2. 744.Opposed notifications: statutory declarations

      3. 745.Opposed notifications: determinations by tribunal

      4. 746.Counteraction notices

      5. 747.Timing of assessments in section 738 cases

    5. Clearance procedure

      1. 748.Application for clearance of transactions

      2. 749.Effect of clearance notification under section 748

    6. Appeals

      1. 750.Appeals against counteraction notices

    7. Interpretation

      1. 751.Interpretation of Part

  29. Part 16 Factoring of income etc

    1. Chapter 1 Transfers of income streams

      1. 752.Application of Chapter

      2. 753.Value of transferred income stream treated as income

      3. 754.Exception: amount otherwise taxed

      4. 755.Exception: transfer by way of security

      5. 756.Partnership shares

      6. 757.Interpretation of Chapter

    2. Chapter 1A Disposals of income streams through partnerships

      1. 757A.Application of Chapter

      2. 757B.Relevant amount to be treated as income

    3. Chapter 2 Finance arrangements

      1. Type 1 arrangements

        1. 758.Type 1 finance arrangement defined

        2. 759.Certain tax consequences not to have effect

        3. 760.Payments treated as borrower's income

        4. 761.Deemed loan relationship if borrower is a company

        5. 762.Deemed loan relationship if borrower is partnership with corporate member

      2. Type 2 arrangements

        1. 763.Type 2 finance arrangement defined

        2. 764.Relevant change in relation to partnership

        3. 765.Certain tax consequences not to have effect

        4. 766.Deemed loan relationship

      3. Type 3 arrangements

        1. 767.Type 3 finance arrangement defined

        2. 768.Certain tax consequences not to have effect

        3. 769.Deemed loan relationship

      4. Exceptions

        1. 770.Exceptions: preliminary

        2. 771.Exceptions

        3. 772.Exceptions: relevant person

        4. 773.Power to make further exceptions

      5. Supplementary

        1. 774.Accounts

        2. 775.Arrangements

        3. 776.Assets

    4. Chapter 3 Loan or credit transactions

      1. 777.Loan or credit transaction defined

      2. 778.Certain payments treated as interest

      3. 779.Tax charged on income transferred

    5. Chapter 4 Disposals of assets through partnerships

      1. 779A.Application of Chapter

      2. 779B.Relevant amount to be treated as income

  30. Part 17 Manufactured payments and repos

    1. Chapter 1 Introduction

      1. 780.Overview of Part

      2. 781.Key definitions

    2. Chapter 2 Manufactured dividends

      1. 782.Meaning of “manufactured dividend”

      2. 783.Treatment of payer of manufactured dividend

      3. 784.Treatment of recipient of manufactured dividend

      4. 785.Treatment of payer: Real Estate Investment Trusts

      5. 786.Treatment of recipient: Real Estate Investment Trusts

      6. 787.Exemption of manufactured dividends

      7. 788.Statements about manufactured dividends

      8. 789.Powers about administrative provisions

    3. Chapter 3 Manufactured overseas dividends

      1. 790.Meaning of “manufactured overseas dividend”

      2. 791.Treatment of payer of manufactured overseas dividend

      3. 792.Company receiving manufactured overseas dividend from UK resident etc

      4. 793.Section 792: amount treated as withheld

      5. 794.Company receiving manufactured overseas dividend from foreign payer

      6. 795.Exemption of manufactured overseas dividends

    4. Chapter 4 Further provision about manufactured payments

      1. Manufactured payments exceeding, or less than, underlying payments

        1. 796.Manufactured dividends: amounts exceeding underlying payments

        2. 797.Manufactured overseas dividends: amounts exceeding underlying payments

        3. 798.Manufactured overseas dividends less than underlying payments

      2. Manufactured payments under arrangements with unallowable purpose

        1. 799.Manufactured payments under arrangements with unallowable purpose

        2. 800.Arrangements with an unallowable purpose

        3. 801.Sections 799 and 800: supplementary

      3. Miscellaneous

        1. 802.Powers about amounts representative of overseas dividends

        2. 803.Power to deal with special cases

        3. 804.Regulation-making powers: general

    5. Chapter 5 Stock lending arrangements and repos

      1. Interpretation

        1. 805.“Stock lending arrangement”

        2. 806.Section 805: supplementary

        3. 807.“Creditor repo”, “creditor quasi-repo”, “debtor repo” and “debtor quasi-repo”

      2. Tax credits: stock lending arrangements and repos

        1. 808.No tax credits for borrower under stock lending arrangement

        2. 809.No tax credits for lender under creditor repo or creditor quasi-repo

        3. 810.No tax credits for borrower under debtor repo or debtor quasi-repo

        4. 811.Arrangements between companies to make distributions

      3. Deemed manufactured payments

        1. 812.Deemed manufactured payments: stock lending arrangements

    6. Chapter 6 Interpretation of Part

      1. 813.The gross amount of a manufactured overseas dividend etc

      2. 814.Other interpretation

  31. PART 17A Manufactured dividends

    1. 814A.Overview of Part

    2. 814B.Key definitions

    3. 814C.Treatment of payer of manufactured dividend

    4. 814D.Treatment of recipient of manufactured dividend

  32. Part 18 Transactions in land

    1. Introduction

      1. 815.Introduction to Part

      2. 816.Meaning of disposing of land

      3. 817.Priority of other tax provisions

    2. Charge to tax on gains from transactions in land

      1. 818.Charge to tax on gains from transactions in land

      2. 819.Gains obtained from land disposals in some circumstances

      3. 820.Person obtaining gain

      4. 821.Company chargeable

      5. 822.Method of calculating gain

    3. Further provisions relevant to the charge

      1. 823.Transactions, arrangements, sales and realisations relevant for Part

      2. 824.Tracing value

      3. 825.Meaning of “another person”

      4. 826.Valuations and apportionments

    4. Exemptions

      1. 827.Gain attributable to period before intention to develop formed

      2. 828.Disposals of shares in companies holding land as trading stock

    5. Recovery of tax

      1. 829.Cases where consideration receivable by person not assessed

      2. 830.Certificates of tax paid etc

    6. Clearances and power to obtain information

      1. 831.Clearance procedure

      2. 832.Power to obtain information

    7. Interpretation

      1. 833.Interpretation of Part

  33. Part 19 Sale and lease-back etc

    1. Chapter 1 Payments connected with transferred land

      1. Introduction

        1. 834.Overview of Chapter

      2. Application of the Chapter

        1. 835.Transferor or associate becomes liable for payment of rent

        2. 836.Transferor or associate becomes liable for payment other than rent

        3. 837.Relevant corporation tax relief

      3. Relief (other than for certain insurance company expenses): restriction and carrying forward

        1. 838.Relevant corporation tax relief: deduction not to exceed commercial rent

      4. Insurance company expenses: restriction and carrying forward of relief

        1. 839.Deduction ... not to exceed commercial rent

        2. 840.Carrying forward parts of payments

        3. 841.Aggregation and apportionment of payments

        4. 842.Payments made for later periods

      5. Interpretation etc

        1. 843.Exclusion of service charges etc

        2. 844.Commercial rent: comparison with rent under a lease

        3. 845.Commercial rent: comparison with payments other than rent

        4. 846.Lease and rent

        5. 847.Associated persons

        6. 848.Land outside the UK

    2. Chapter 2 New lease of land after assignment or surrender

      1. Introduction

        1. 849.Overview of Chapter

      2. Application of the Chapter

        1. 850.New lease after assignment or surrender

      3. Taxation of consideration

        1. 851.Taxation of consideration

        2. 852.Position where new lease does not include all original property

      4. Relief for rent under new lease

        1. 853.Relief for rent under new lease

      5. New lease treated as ending

        1. 854.New lease treated as ending

        2. 855.Position where rent reduces

        3. 856.Position where lease may be ended

        4. 857.Position where lease may be varied

        5. 858.Lease treated as ending: rentcharge

      6. Lease varied to provide for increased rent

        1. 859.Lease varied to provide for increased rent

      7. Interpretation

        1. 860.Relevant corporation tax relief

        2. 861.Linked persons

        3. 862.Lease, lessee, lessor and rent

    3. Chapter 3 Leased trading assets

      1. Introduction

        1. 863.Overview of Chapter

      2. Application of the Chapter

        1. 864.Leased trading assets

      3. Relief: restriction and carrying forward

        1. 865.Tax deduction not to exceed commercial rent

        2. 866.Long funding finance leases

        3. 867.Commercial rent

      4. Interpretation

        1. 868.Lease

        2. 869.Relevant asset

    4. Chapter 4 Leased assets: capital sums

      1. Introduction

        1. 870.Overview of Chapter

      2. Application of the Chapter

        1. 871.Application of the Chapter

        2. 872.Payment under lease

        3. 873.Sum obtained

      3. Charge to corporation tax

        1. 874.Charge to corporation tax

        2. 875.Hire-purchase agreements

        3. 876.Adjustments where sum obtained before payment made

      4. Obtaining of sum

        1. 877.Sum obtained in respect of interest

        2. 878.Sum obtained in respect of lessee's interest

        3. 879.Disposal of interest to associate

      5. Apportionment

        1. 880.Apportionment of payments made and of sums obtained

        2. 881.Manner of apportionment

      6. Interpretation

        1. 882.Associates

        2. 883.Capital sum

        3. 884.Lease

        4. 885.Relevant asset

        5. 886.Relevant tax relief

  34. Part 20 Tax avoidance involving leasing plant or machinery

    1. Chapter 1 Restrictions on use of losses in leasing partnerships

      1. 887.When restrictions on leasing partnership losses under this Chapter apply

      2. 888.Restrictions on leasing partnership losses

      3. 889.Interpretation of Chapter

    2. Chapter 2 Capital payments in respect of leases treated as income

      1. 890.Capital payments in respect of leases treated as income

      2. 891.Apportionments for leases of plant or machinery and other property

      3. 892.Deduction where failure to make relevant capital payment expected

      4. 893.Meaning of “capital payment”, “relevant capital payment” etc

      5. 894.Other interpretation of Chapter

    3. Chapter 3 Consideration for taking over payment obligations as lessee treated as income

      1. 894A.Consideration for taking over payment obligations as lessee treated as income

  35. Part 21 Leasing arrangements: finance leases and loans

    1. Chapter 1 Introduction

      1. Introduction

        1. 895.Overview of Part

      2. Meaning of expressions about rent

        1. 896.Normal rent

        2. 897.Accountancy rental earnings

        3. 898.Rental earnings

    2. Chapter 2 Finance leases with return in capital form

      1. Introduction

        1. 899.Arrangements to which this Chapter applies

        2. 900.Purposes of this Chapter

      2. Leases to which this Chapter applies

        1. 901.Application of this Chapter

        2. 902.The conditions referred to in section 901(1)

        3. 903.Provisions supplementing section 902

        4. 904.The arrangements and circumstances referred to in section 902(8)

      3. Current lessor taxed by reference to accountancy rental earnings

        1. 905.Current lessor taxed by reference to accountancy rental earnings

      4. Reduction of taxable rent by cumulative rental excesses

        1. 906.Reduction of taxable rent by cumulative rental excesses: introduction

        2. 907.Meaning of “accountancy rental excess” and “cumulative accountancy rental excess”

        3. 908.Reduction of taxable rent by the cumulative accountancy rental excess

        4. 909.Meaning of “normal rental excess” and “cumulative normal rental excess”

        5. 910.Reduction of taxable rent by the cumulative normal rental excess

      5. Relief for bad debts by reduction of cumulative rental excesses

        1. 911.Relief for bad debts: reduction of cumulative accountancy rental excess

        2. 912.Recovery of bad debts following reduction under section 911

        3. 913.Relief for bad debts: reduction of cumulative normal rental excess

        4. 914.Recovery of bad debts following reduction under section 913

      6. Effect of disposals

        1. 915.Effect of disposals of leases: general

        2. 916.Assignments on which neither a gain nor a loss accrues

      7. Capital allowances: clawback of major lump sum

        1. 917.Effect of capital allowances: introduction

        2. 918.Cases where expenditure taken into account under Part 2, 5 or 8 of CAA 2001

        3. 919.Cases where expenditure taken into account under other provisions of CAA 2001

        4. 920.Capital allowances deductions: waste disposal and cemeteries

        5. 921.Capital allowances deductions: films

        6. 922.Contributors to capital expenditure

      8. Schemes to which this Chapter does not at first apply

        1. 923.Pre-26 November 1996 schemes where this Chapter does not at first apply

        2. 924.Post-25 November 1996 schemes to which Chapter 3 applied first

    3. Chapter 3 Other finance leases

      1. Introduction

        1. 925.Introduction to Chapter

        2. 926.Purpose of this Chapter

      2. Current lessor taxed by reference to accountancy rental earnings

        1. 927.Leases to which this Chapter applies

        2. 928.Current lessor taxed by reference to accountancy rental earnings

      3. Application of provisions of Chapter 2 for purposes of this Chapter

        1. 929.Application of provisions of Chapter 2 for purposes of this Chapter

    4. Chapter 4 Supplementary provisions

      1. 930.Pre-26 November 1996 schemes and post-25 November 1996 schemes

      2. 931.Time apportionment where periods of account do not coincide

      3. 932.Periods of account and related periods of account and accounting periods

      4. 933.Connected persons

      5. 934.Assets which represent the leased asset

      6. 935.Parent undertakings and consolidated group accounts

      7. 936.Assessments and adjustments

      8. 937.Interpretation of Part

  36. Part 21A Risk transfer schemes

    1. Introduction

      1. 937A.Overview

      2. 937B.Group schemes and single company schemes

    2. Basic definitions

      1. 937C.Meaning of “risk transfer scheme”

      2. 937D.Meaning of “the scheme rate, index or value”

      3. 937E.Scheme losses and scheme profits

      4. 937F.Ring-fenced scheme losses and relevant scheme profits

    3. Treatment of ring-fenced scheme losses

      1. 937G.Ring-fenced scheme loss: treatment in period in which made

      2. 937H.Ring-fenced scheme loss: treatment in subsequent periods

    4. A company's losses pool and profits pool

      1. 937I.A company's losses pool and profits pool

    5. General

      1. 937J.Tax capacity assumption

      2. 937K.Meaning of “associated with”

      3. 937L.Interpretation of references to economic losses and profits

      4. 937M.Foreign currency accounting

      5. 937N.Meaning of “scheme”

      6. 937NA.Priority

    6. Power to amend this Part

      1. 937O.Power to amend this Part in its application to dealers in securities

  37. Part 21B Group mismatch schemes

    1. 938A.Losses and profits from group mismatch schemes to be disregarded

    2. 938B.Meaning of “a group mismatch scheme” and “the scheme group”

    3. 938C.Meaning of “scheme loss” and “scheme profit”

    4. 938D. Meaning of “relevant tax advantage” etc and “the scheme period”

    5. 938E.Meaning of “group”

    6. 938F.Meaning of references to economic profits and losses

    7. 938G.Tax capacity assumption

    8. 938H.Meaning of “scheme”

    9. 938I.Schemes involving repos or quasi-repos

    10. 938J.Schemes involving finance arrangements

    11. 938K.Trading income

    12. 938L.Foreign companies and foreign permanent establishments

    13. 938M.Controlled foreign companies

    14. 938N.Priority

  38. PART 21BA Tax mismatch schemes

    1. 938O.Losses and profits from tax mismatch scheme to be disregarded

    2. 938P.Meaning of “tax mismatch scheme”

    3. 938Q.Meaning of “scheme loss” and “scheme profit”

    4. 938R.Meaning of “relevant tax advantage” etc and “the scheme period”

    5. 938S.Meaning of references to economic profits and losses

    6. 938T.Tax capacity assumption

    7. 938U.Meaning of “scheme”

    8. 938V.Priority

  39. Part 21C Tainted charity donations

    1. Introduction

      1. 939A.Overview of Part

      2. 939B.Relievable charity donations

    2. Tainted donations

      1. 939C. Tainted donations

      2. 939D.Circumstances in which financial advantage deemed to be obtained

      3. 939E.Certain financial advantages to be ignored

    3. Removal of reliefs

      1. 939F. Removal of corporation tax relief in respect of tainted donations etc

    4. Supplementary

      1. 939G.Connected charities

      2. 939H.Connected persons

      3. 939I.Minor definitions

  40. Part 22 Miscellaneous provisions

    1. Chapter 1 Transfers of trade without a change of ownership

      1. Introduction

        1. 940A.Overview of Chapter

        2. 940B.Meaning of “transfer of a trade” and related expressions

      2. Transfers to which Chapter applies

        1. 940C.Transfers to which Chapter applies

        2. 941.The ownership condition

        3. 942.Options that may be applied for the purposes of the ownership condition

        4. 943.The tax condition

      3. Effect of Chapter in relation to transfers to which it applies

        1. 943A.Disapplication of section 39

        2. 944.Modified application of section 45

        3. 944A.Modified application of section 45A

        4. 944B.Modified application of section 45B

        5. 944C.Modified application of section 45F

        6. 944D.Modified application of section 303B

        7. 944E.Modified application of section 303D

        8. 945.Cases in which predecessor retains more liabilities than assets

        9. 946.Rules for determining “L”

        10. 947.Rules for determining “A”

        11. 948.Modified application of CAA 2001

        12. 949.Dual resident investing companies

        13. 950.Transfers of trades involving business of leasing plant or machinery

      4. Supplementary

        1. 951.Part of trade treated as separate trade

        2. 952.Apportionment if part of trade treated as separate trade

        3. 953.Application of Chapter to further transfers of a trade

    2. Chapter 2 Transfers of trade to obtain balancing allowances

      1. 954.Transfer of activities on complete cessation of trade

      2. 955.Transfer of activities on part cessation of trade

      3. 956.Apportionment if part of trade treated as separate trade

      4. 957.Chapter 2: supplementary

    3. Chapter 3 Transfer of relief within partnerships

      1. 958.Application

      2. 959.Arrangements for transfer of relief

      3. 960.Restrictions on use of reliefs

      4. 961.Non-trading profits and losses

      5. 962.Interpretation of Chapter

    4. Chapter 4 Surrender of tax refund within group

      1. 963.Power to surrender tax refund

      2. 964.Effects of surrender of tax refund

      3. 965.Interest on tax overpaid or underpaid

      4. 966.Payments for surrendered tax refunds

    5. Chapter 5 Set off of income tax deductions against corporation tax

      1. 967.Deductions from payments received by UK resident companies

      2. 968.Deductions from payments received by non-UK resident companies

    6. Chapter 6 Collection etc of tax from UK representatives of non-UK resident companies

      1. 969.Introduction to Chapter

      2. 970.Obligations and liabilities in relation to corporation tax

      3. 971.Exceptions

      4. 972.Interpretation of Chapter

    7. Chapter 7 Recovery of unpaid corporation tax due from non-UK resident company

      1. 973.Introduction to Chapter

      2. 974.Case in which this Chapter applies

      3. 975.Meaning of “the relevant period”

      4. 976.Meaning of “related company”

      5. 977.Notice requiring payment of unpaid tax

      6. 978.Time limit for giving notice

      7. 979.Amount payable in consortium case

      8. 980.Chapter 7: supplementary

    8. Chapter 8 Exemptions

      1. Trade unions and employers' associations

        1. 981.Exemption for trade unions and eligible employers' associations

        2. 982.Qualifying income or gains

        3. 983.Meaning of “trade union” and “eligible employers' association”

      2. Local authorities etc

        1. 984.Local authorities and local authority associations

      3. Health service bodies

        1. 985.Health service bodies

        2. 986.Meaning of “health service body”

        3. 987.NHS foundation trusts

      4. Police

        1. 987A. Chief constables etc (England and Wales)

      5. Education Authority of Northern Ireland

        1. 987B.Education Authority of Northern Ireland

      6. Northern Ireland Housing Executive

        1. 987C.Northern Ireland Housing Executive

      7. Reserve Bank of India and State Bank of Pakistan

        1. 988.Issue departments of the Reserve Bank of India and the State Bank of Pakistan

      8. Agricultural societies

        1. 989.Agricultural societies

    9. Chapter 9 Other miscellaneous provisions

      1. UK Economic Interest Groupings and European Economic Interest Groupings

        1. 990. UK Economic Interest Groupings and European Economic Interest Groupings

      2. Harbour reorganisation schemes

        1. 991.Harbour reorganisation schemes: corporation tax

        2. 992.Harbour reorganisation schemes: capital allowances etc

        3. 993.Harbour reorganisation schemes: chargeable gains

        4. 994.Transfer of part of trade

        5. 995.Interpretation of sections 991 to 994

      3. Groups: use of different accounting practices

        1. 996.Use of different accounting practices within a group of companies

      4. Sporting testimonial payments and associated payments

        1. 996A.Deductions from total profits for sporting testimonial payments and associated payments

  41. Part 23 Company distributions

    1. Chapter 1 Introduction

      1. 997.Overview of Part

    2. Chapter 2 Matters which are distributions

      1. Introduction

        1. 998.Overview of Chapter

        2. 999.Priority of negative rules

      2. Meaning of “distribution”

        1. 1000.Meaning of “distribution”

        2. 1001.Provisions related to paragraphs A to H in section 1000(1)

      3. Distributions, other than dividends, in respect of shares

        1. 1002.Exceptions for certain transfers of assets or liabilities between a company and its members

      4. Redeemable share capital

        1. 1003.Redeemable share capital

      5. Securities issued otherwise than for new consideration

        1. 1004.Securities issued otherwise than for new consideration

      6. Distributions in respect of non-commercial securities

        1. 1005.Meaning of “non-commercial securities”

        2. 1006.Distributions exceeding consideration received for issue of security

        3. 1007.Securities issued at premium representing new consideration

        4. 1008.Consideration for issue of security exceeding amount of principal

      7. Exceptions to section 1008

        1. 1009.Securities reflecting dividends on certain shares etc: exclusion of section 1008

        2. 1010.Meaning of “qualifying index” in section 1009

        3. 1011.Meaning of “associated company” in section 1009

        4. 1012.Hedging arrangements

        5. 1013.Exception to section 1012

        6. 1014.Meaning of “hedging arrangements”

      8. Distributions in respect of special securities

        1. 1015.Meaning of “special securities”

        2. 1016.Meaning of “equity note” in section 1015

        3. 1017.Section 1015: other interpretation

        4. 1018.The principal secured: special securities

        5. 1019.Relevant alternative finance return

      9. Transfers of assets or liabilities treated as distributions

        1. 1020.Transfers of assets or liabilities treated as distributions

        2. 1021.Section 1020: exceptions

      10. Bonus issue following repayment of share capital

        1. 1022.Bonus issue following repayment of share capital treated as distribution

        2. 1023.Exceptions to section 1022(3)

      11. Interpretation of references to repayment of share capital

        1. 1024.Premiums paid on redemption of share capital

        2. 1025.Share capital issued at a premium representing new consideration

        3. 1026.Distributions following a bonus issue

        4. 1027.Cap on amount of distributions affected by section 1026

        5. 1027A.Distributions following reduction of share capital

        6. 1028.Certain payments connected with exempt distributions

    3. Chapter 3 Matters which are not distributions

      1. Introduction

        1. 1029.Overview of Chapter

      2. Distributions in a winding up

        1. 1030.Distribution in respect of share capital in a winding up

      3. Distributions prior to dissolution of company

        1. 1030A.Distributions in respect of share capital prior to dissolution of company

        2. 1030B. Section 1030A: effect of company not being dissolved, etc

      4. Distribution as part of a cross-border merger

        1. 1031.Distribution as part of a cross-border merger

      5. Payments of interest

        1. 1032.Interest etc paid in respect of certain securities

      6. ...

        1. 1032A.Payment in respect of tier two capital

      7. Purchase of own shares

        1. 1033.Purchase by unquoted trading company of own shares

        2. 1034.Requirements as to residence

        3. 1035.Requirement as to period of ownership

        4. 1036.Determining the period of ownership

        5. 1037.Requirement as to reduction of seller's interest as shareholder

        6. 1038.Exclusion of other deductions

        7. 1039.Requirements where purchasing company is a member of a group

        8. 1040.Determining whether interests as shareholders in a group are substantially reduced

        9. 1041.Section 1040: effect of entitlement to profits

        10. 1042.Other requirements

        11. 1043.Relaxation of requirements in certain cases

      8. Purchase of own shares: supplementary

        1. 1044.Advance clearance of payments by Commissioners

        2. 1045.Advance clearance: supplementary

        3. 1046.Information and returns

        4. 1047.Meaning of “group” and “51% subsidiary” in sections 1033 to 1047

        5. 1048.Sections 1033 to 1047: other interpretation

      9. Stock dividends

        1. 1049.Stock dividends

        2. 1050.Application of section 1049 where bonus share capital is converted etc

        3. 1051.“Bonus share capital” and “in lieu of a cash dividend”

        4. 1052.Share capital to which section 1049 applies: returns

        5. 1053.Return periods

      10. Building society payments

        1. 1054.Building society payments

      11. Registered society payments

        1. 1055. Registered societies : interest and share dividends

        2. 1056.Dividend or bonus relating to transactions

      12. Payments made by UK agricultural or fishing co-operatives

        1. 1057.UK agricultural or fishing co-operatives: interest and share dividends

        2. 1058.Meaning of “UK agricultural or fishing co-operative”

      13. Supplementary provisions

        1. 1059.Associated persons

        2. 1060.Associated persons: trustees

        3. 1061.Associated persons: personal representatives

        4. 1062.Connected persons

        5. 1063.Section 1062: supplementary

    4. Chapter 4 Special rules for distributions made by certain companies

      1. Close companies

        1. 1064.Certain expenses of close companies treated as distributions

        2. 1065.Exception for benefits treated as employment income etc

        3. 1066.Exception for certain transfers between UK resident companies

        4. 1067.Companies acting in concert or under arrangements

        5. 1068.Meaning of “participator” in sections 1064 to 1067

        6. 1069.Additional persons treated as participators

      2. Companies carrying on a mutual business

        1. 1070.Companies carrying on a mutual business

      3. Companies not carrying on a business

        1. 1071.Companies not carrying on a business

      4. Members of a 90% group

        1. 1072.Members of a 90% group

    5. Chapter 5 Demergers

      1. Introduction

        1. 1073.Key terms etc

        2. 1074.Purpose of provisions about demergers

      2. Exempt distributions

        1. 1075.Exempt distributions

        2. 1076.Transfer of shares in subsidiaries to members

        3. 1077.Transfer by distributing company and issue of shares by transferee company

        4. 1078.Division of business in a cross-border transfer

        5. 1079.“The distributing company”

        6. 1080.Meaning of “relevant company”

      3. Exemption by virtue of section 1076 or 1077: conditions

        1. 1081.General conditions

        2. 1082.Conditions for distributions within section 1076(a)

        3. 1083.Conditions for distributions within section 1077(1)

        4. 1084.Cases where condition K does not apply

        5. 1085.Conditions to be met if the distributing company is a 75% subsidiary

      4. Chargeable payments

        1. 1086.Chargeable payments connected with exempt distributions

        2. 1087.Chargeable payments not deductible in calculating profits

        3. 1088.Meaning of “chargeable payment”

        4. 1089.Meaning of “chargeable payment”: unquoted companies

        5. 1090.Meaning of “company concerned in an exempt distribution”

      5. Advance clearance

        1. 1091.Advance clearance of distributions

        2. 1092.Advance clearance of payments

        3. 1093.Requirements relating to applications for clearance

        4. 1094.Decision of the Commissioners or tribunal

      6. Information and returns

        1. 1095.Exempt distributions: returns

        2. 1096.Chargeable payments etc: returns

        3. 1097.Information about person for whom a payment is received

      7. Supplementary

        1. 1098.Meaning of “unquoted company”

        2. 1099.Other definitions etc

    6. Chapter 6 Information and returns: further provisions

      1. General duties to provide information

        1. 1100. Certain distributions: right to request a statement

        2. 1101. Other distributions etc: returns and information

        3. 1102. Other distributions etc: additional information

        4. 1103.Power to modify or replace sections 1101 and 1102

      2. Companies and nominees required to provide tax certificates

        1. 1104.Company distributing dividend or interest: duty to provide tax certificates

        2. 1105.Duties of nominees

        3. 1106.Meaning of “tax certificate” etc

        4. 1107.Penalties

        5. 1108.Alternative means of compliance with sections 1104 and 1105

    7. Chapter 7 Tax credits

      1. 1109.Tax credits for certain recipients of exempt qualifying distributions

      2. 1110.Recovery of overpaid tax credit etc

      3. 1111.Section 1110: supplementary

    8. Chapter 8 Interpretation of Part

      1. 1112.Arrangements between companies

      2. 1113.“In respect of shares”

      3. 1114.“In respect of securities”

      4. 1115.“New consideration”

      5. 1116.References to married persons, or civil partners, living together

      6. 1117.Other interpretation

  42. Part 24 Corporation Tax Acts definitions etc

    1. Chapter 1 Definitions

      1. 1118.Introduction to Chapter

      2. 1119.The definitions

      3. 1120.“Bank”

      4. 1121.“Company”

      5. 1122.“Connected” persons

      6. 1123.“Connected” persons: supplementary

      7. 1124.“Control”

      8. 1125.“Farming” and related expressions

      9. 1126.“Franked investment income”

      10. 1127.“Generally accepted accounting practice” and related expressions

      11. 1128.“Grossing up”

      12. 1129.“Hire-purchase agreement”

      13. 1130.“Local authority”

      14. 1131.“Local authority association”

      15. 1132.“Offshore installation”

      16. 1133.Regulations about the meaning of “offshore installation”

      17. 1134.“Oil and gas exploration and appraisal”

      18. 1135.“Property investment LLP”

      19. 1136.“Qualifying distribution”

      20. 1137.“Recognised stock exchange”

      21. 1138.“Research and development”

      22. 1139.“Tax advantage”

      23. 1140.“Unauthorised unit trust”

    2. Chapter 2 Permanent establishments

      1. General

        1. 1141.Permanent establishments of companies

      2. Circumstances where there is no permanent establishment

        1. 1142.Agent of independent status

        2. 1143.Preparatory or auxiliary activities

        3. 1144.Alternative finance arrangements

      3. Brokers

        1. 1145.The independent broker conditions

      4. Investment managers

        1. 1146.The independent investment manager conditions

        2. 1147.Investment managers: the 20% rule

        3. 1148.Section 1147: interpretation

        4. 1149.Application of 20% rule to collective investment schemes

        5. 1150.Meaning of “investment manager” and “investment transaction”

      5. Lloyd's agents

        1. 1151.Lloyd's agents

      6. Supplementary

        1. 1152.Investment managers: disregard of certain chargeable profits

        2. 1153.Miscellaneous

    3. Chapter 3 Subsidiaries

      1. 1154.Meaning of “51% subsidiary”, “75% subsidiary” and “90% subsidiary”

      2. 1155.Indirect ownership of ordinary share capital

      3. 1156.Calculation of amounts owned indirectly: main rules

      4. 1157.Adding fractions together

    4. Chapter 4 Investment trusts

      1. 1158.Meaning of “investment trust”

      2. 1159.Approval

      3. 1160.Calculation of income

      4. 1161.The income retention condition: exceptions

      5. 1162.The 15% holding limit: exceptions

      6. 1163.Basic meaning of “holding in a company”

      7. 1164.More about the meaning of “holding in a company”

      8. 1165.Other interpretation

    5. Chapter 5 Other Corporation Tax Acts provisions

      1. 1166.Scotland

      2. 1167.Sources of income within the charge to corporation tax or income tax

      3. 1168.Payment of dividends

      4. 1169.Settlements and trustees

      5. 1170.Territorial sea of the United Kingdom

      6. 1171.Orders and regulations

      7. 1172.Apportionment to different periods

      8. 1173.Miscellaneous charges

  43. Part 25 Definitions for purposes of Act and final provisions

    1. Definitions for the purposes of Act

      1. 1174.Abbreviated references to Acts

      2. 1175.Claims and elections

      3. 1176.Meaning of “connected” persons and “control”

    2. Final provisions

      1. 1177.Minor and consequential amendments

      2. 1178.Power to make consequential provision

      3. 1179.Power to undo changes

      4. 1180.Transitional provisions and savings

      5. 1181.Repeals and revocations

      6. 1182.Index of defined expressions

      7. 1183.Extent

      8. 1184.Commencement

      9. 1185.Short title

  44. Schedules

    1. SCHEDULE 1

      Minor and consequential amendments

      1. Part 1 Income and Corporation Taxes Act 1988

        1. 1.The Income and Corporation Taxes Act 1988 is amended as...

        2. 2.Omit section 6(4) (the charge to corporation tax and exclusion...

        3. 3.Omit section 7 (treatment of certain payments and repayment of...

        4. 4.Omit section 11(3) and (4) (companies not resident in the...

        5. 5.Omit sections 13 to 13A (small companies' relief).

        6. 6.Omit section 14 (qualifying distributions).

        7. 7.(1) Omit section 24 (which has come to apply only...

        8. 8.Omit section 56(3)(c) (exemption for transactions in deposits).

        9. 9.Minor and consequential amendments

        10. 10.Minor and consequential amendments

        11. 11.Omit section 116 (arrangements for transferring relief).

        12. 12.Omit sections 118 to 118ZD (restrictions on relief for losses...

        13. 13.In section 187(10) (interpretation of sections 185 and 186 etc)...

        14. 14.Omit Chapter 2 of Part 6 (matters which are distributions)....

        15. 15.Omit Chapter 3 of Part 6 (matters which are not...

        16. 16.Omit section 231 (tax credits for certain recipients of qualifying...

        17. 17.Omit section 231AA (no tax credit for borrower under stock...

        18. 18.Omit section 231AB (no tax credit for original owner under...

        19. 19.In section 231B(12) (consequences of certain arrangements to pass on...

        20. 20.Omit section 234 (information relating to distributions).

        21. 21.Omit section 234A (information relating to distributions: further provisions).

        22. 22.Omit Chapter 6 of Part 6 (miscellaneous and supplemental).

        23. 23.In section 337A (computation of company's profits or income: exclusion...

        24. 24.Omit section 338 (charges on income deducted from total profits)....

        25. 25.Omit section 338A (meaning of “charges on income”).

        26. 26.Omit section 339 (charges on income: donations to charity).

        27. 27.Omit section 342 (tax on company in liquidation).

        28. 28.Omit section 342A (tax on companies in administration).

        29. 29.Omit section 343 (company reconstructions without a change of ownership)....

        30. 30.Omit section 343ZA (transfers of trade to obtain balancing allowances)....

        31. 31.Omit section 343A (company reconstructions involving business of leasing plant...

        32. 32.Omit section 344 (company reconstructions: supplemental).

        33. 33.In section 369(6) (mortgage interest payable under deduction of tax)...

        34. 34.Omit Chapter 2 of Part 10 (loss relief).

        35. 35.Omit section 397 (restriction of loss relief in case of...

        36. 36.In section 398 (transactions in deposits) for “section 396” substitute...

        37. 37.Omit section 399 (dealings in commodity futures).

        38. 38.Omit section 400 (write-off of government investment).

        39. 39.Omit Chapter 4 of Part 10 (group relief).

        40. 40.Omit Chapter 1 of Part 11 (close companies: interpretation).

        41. 41.Omit Chapter 2 of Part 11 (close companies: charges to...

        42. 42.Minor and consequential amendments

        43. 43.Minor and consequential amendments

        44. 44.Minor and consequential amendments

        45. 45.Minor and consequential amendments

        46. 46.Minor and consequential amendments

        47. 47.Minor and consequential amendments

        48. 48.Minor and consequential amendments

        49. 49.Minor and consequential amendments

        50. 50.Minor and consequential amendments

        51. 51.Minor and consequential amendments

        52. 52.Omit section 467 (exemption for trade unions and employers' associations)....

        53. 53.Omit section 468 (authorised unit trusts).

        54. 54.Omit section 468A (open-ended investment companies).

        55. 55.Omit section 469 (other unit trusts).

        56. 56.Omit section 469A (court common investment funds).

        57. 57.Omit section 477A (building societies: loan relationships).

        58. 58.Omit section 486 (industrial and provident societies and co-operative associations)....

        59. 59.Omit section 488 (co-operative housing associations).

        60. 60.Omit section 489 (self-build societies).

        61. 61.Omit section 490 (companies carrying on a mutual business or...

        62. 62.Omit section 492 (treatment of oil extraction activities etc for...

        63. 63.(1) Omit section 493 (valuation of oil disposed of or...

        64. 64.Omit sections 494 to 494A (loan relationships etc, sale and...

        65. 65.(1) Omit section 495 (regional development grants).

        66. 66.(1) Omit section 496 (tariff receipts and tax-exempt tariffing receipts)....

        67. 67.Omit section 496B (ring fence expenditure supplement).

        68. 68.Omit sections 500 to 501B (deduction of PRT, interest on...

        69. 69.(1) Omit section 502 (interpretation of Chapter 5).

        70. 70.Omit Chapter 5A of Part 12 (special rules for long...

        71. 71.Omit section 503 (letting of furnished holiday accommodation).

        72. 72.Omit section 505 (charitable companies: general).

        73. 73.Omit section 506 (charitable and non-charitable expenditure).

        74. 74.Omit section 506A (transactions with substantial donors).

        75. 75.Omit section 506B (section 506A: exceptions).

        76. 76.Omit section 506C (sections 506A and 506B: supplemental).

        77. 77.Omit section 507 (the National Heritage Memorial Fund, the Historic...

        78. 78.Omit section 508 (scientific research organisations).

        79. 79.Omit section 510 (agricultural societies).

        80. 80.Omit section 510A (European Economic Interest Groupings).

        81. 81.Omit section 511(7) (the Gas Council).

        82. 82.Omit section 513 (British Airways Board and National Freight Corporation)....

        83. 83.Omit section 517 (issue departments of Reserve Bank of India...

        84. 84.Omit section 518 (harbour reorganisation schemes).

        85. 85.Omit section 519 (local authorities).

        86. 86.Omit section 519A (health service bodies).

        87. 87.In section 552A(11) (tax representatives) for “Section 839” substitute “...

        88. 88.Omit Chapter 5A of Part 13 (share loss relief).

        89. 89.Omit section 587B (gifts of shares, securities and real property...

        90. 90.Omit section 587BA (qualifying interests in land held jointly).

        91. 91.Omit section 587C (supplementary provision for gifts of real property)....

        92. 92.Omit section 687A (discretionary payments by trustees to companies).

        93. 93.Omit section 689B (order in which trustees' expenses are to...

        94. 94.Omit Chapter 1 of Part 17 (cancellation of corporation tax...

        95. 95.Omit section 736A (manufactured dividends and interest).

        96. 96.Omit section 736B (deemed manufactured payments in the case of...

        97. 97.In section 749B(3) (interests in companies) for “Part VI” substitute...

        98. 98.In section 750(3)(c)(i) (territories with a lower level of taxation)...

        99. 99.In section 751(6)(b) (accounting periods and creditable tax) for “section...

        100. 100.In section 755D(10) (“control” and the two “40 per cent”...

        101. 101.(1) Amend section 756 (interpretation and construction of Chapter 4)...

        102. 102.Omit sections 767A to 769 (change in ownership of company)....

        103. 103.Minor and consequential amendments

        104. 104.(1) Omit sections 774A to 774G (factoring of income receipts...

        105. 105.Omit sections 776 to 778 (transactions in land).

        106. 106.(1) Omit sections 779 to 785 (sale and lease-back etc)....

        107. 107.Omit section 785ZA (restrictions on use of losses: leasing partnerships)....

        108. 108.Omit section 785ZB (section 785ZA: definitions).

        109. 109.Omit section 785B (plant and machinery leases: capital receipts to...

        110. 110.Omit section 785C (section 785B: interpretation).

        111. 111.Omit section 785D (section 785B: lease of plant and machinery...

        112. 112.Omit section 785E (section 785B: expectation that relevant capital payment...

        113. 113.(1) Omit section 786 (transactions associated with loans or credit)....

        114. 114.In section 806A(2) (eligible unrelieved foreign tax dividends: introductory)—

        115. 115.Omit section 808 (restriction on deduction of interest or dividends...

        116. 116.Minor and consequential amendments

        117. 117.(1) Amend section 826 (interest on tax overpaid) as follows....

        118. 118.(1) Amend section 828 (orders and regulations made by the...

        119. 119.Omit section 830(1) (territorial sea of the United Kingdom).

        120. 120.In section 831(3) (interpretation of ICTA) at the appropriate place...

        121. 121.Omit section 832 (interpretation of the Corporation Tax Acts).

        122. 122.Omit section 834 (interpretation of the Corporation Tax Acts).

        123. 123.Omit section 834A (miscellaneous charges).

        124. 124.Omit section 834B (meaning of “UK property business” and “overseas...

        125. 125.Omit section 834C (total profits).

        126. 126.Omit section 837A (meaning of “research and development”).

        127. 127.Omit section 837B (meaning of “oil and gas exploration and...

        128. 128.Omit section 837C (meaning of “offshore installation”).

        129. 129.Omit section 838 (subsidiaries).

        130. 130.Omit section 839 (connected persons).

        131. 131.Omit section 840 (meaning of “control” in certain contexts).

        132. 132.Omit section 840ZA (meaning of “tax advantage”).

        133. 133.Omit section 840A (banks).

        134. 134.Omit section 841 (meaning of “recognised stock exchange” etc).

        135. 135.Omit section 842 (investment trusts).

        136. 136.Omit section 842A (local authorities).

        137. 137.Omit section 842B (meaning of “property investment LLP”).

        138. 138.In paragraph 5(2) of Schedule 10 (further provisions relating to...

        139. 139.Omit Schedule 17 (dual resident investing companies).

        140. 140.Omit Schedule 18 (group relief: equity holders and profits or...

        141. 141.Omit Schedule 18A (group relief: overseas losses of non-resident companies)....

        142. 142.(1) Amend Schedule 19B (petroleum extraction activities: exploration expenditure supplement)...

        143. 143.Omit Schedule 19C (petroleum extraction activities: ring fence expenditure supplement)....

        144. 144.Omit Schedule 20 (charitable companies: qualifying investments and loans).

        145. 145.Omit Schedule 23A (manufactured dividends and interest).

        146. 146.(1) Amend Schedule 24 (assumptions for calculating chargeable profits etc)...

        147. 147.(1) Amend Schedule 25 (cases where section 747(3) of ICTA...

        148. 148.(1) Amend Schedule 26 (reliefs against liability for tax in...

        149. 149.Omit Schedule 28A (change in ownership of company with investment...

      2. Part 2 Other enactments

        1. Finance Act 1930

          1. 150.(1) Section 42 of the Finance Act 1930 (relief from...

        2. Finance Act (Northern Ireland) 1954 (c. 23(N.I.))

          1. 151.(1) Section 11 of the Finance Act (Northern Ireland) 1954...

        3. Taxes Management Act 1970

          1. 152.The Taxes Management Act 1970 is amended as follows.

          2. 153.In section 12AB(5) (partnership return to include partnership statement), in...

          3. 154.In section 12B(4A) (records to be kept for purposes of...

          4. 155.In section 59E(11) (further provision as to when corporation tax...

          5. 156.(1) Amend section 87A (interest on overdue corporation tax etc)...

          6. 157.(1) Amend section 98 (special returns etc) as follows.

          7. 158.(1) Amend section 109 (corporation tax on close companies in...

          8. 159.In section 118(1) (interpretation)— (a) in the definition of “company”...

        4. Oil Taxation Act 1975

          1. 160.The Oil Taxation Act 1975 is amended as follows.

          2. 161.(1) Amend section 3 (allowance of expenditure) as follows.

          3. 162.(1) Amend section 5 (allowance of abortive exploration expenditure) as...

          4. 163.In section 6(4)(b) (allowance of unrelievable loss from abandoned field)...

          5. 164.In section 21(2) (citation etc)— (a) at the appropriate place...

          6. 165.(1) Amend Schedule 3 (petroleum revenue tax: miscellaneous provisions) as...

          7. 166.(1) Amend Schedule 4 (provisions supplementary to sections 3 and...

          8. 167.In Schedule 5 (allowance of expenditure) in paragraph 2B(2) for...

        5. Solicitors (Northern Ireland) Order 1976 (S.I. 1976/582 (N.I. 12))

          1. 168.In paragraph 38(3) of Schedule 1A to the Solicitors (Northern...

        6. Alcoholic Liquor Duties Act 1979

          1. 169.In section 36B(8) of the Alcoholic Liquor Duties Act 1979...

        7. Finance Act 1980

          1. 170.The Finance Act 1980 is amended as follows.

          2. 171.In section 107(7) (transmedian fields) after “meaning of” insert “...

          3. 172.(1) Amend Schedule 17 (transfers of interests in oil fields)...

        8. Betting and Gaming Duties Act 1981

          1. 173.The Betting and Gaming Duties Act 1981 is amended as...

          2. 174.In section 20(6)(a) (expenditure on bingo winnings) for “section 839...

          3. 175.In section 21(7) (gaming machine licences) for “Section 839 of...

        9. Finance Act 1982

          1. 176.The Finance Act 1982 is amended as follows.

          2. 177.In section 134(1) (alternative valuation of ethane used for petrochemical...

          3. 178.(1) In Schedule 19 (supplementary provisions relating to APRT) omit...

        10. Finance Act 1983

          1. 179.In Schedule 8 to the Finance Act 1983 (reliefs for...

        11. Oil Taxation Act 1983

          1. 180.The Oil Taxation Act 1983 is amended as follows.

          2. 181.In section 6(4A)(b) (amounts which are not chargeable tariff receipts)...

          3. 182.In section 15(4) (interpretation etc) for “Section 839 of the...

          4. 183.In paragraph 8(2B)(b) of Schedule 1 (allowable expenditure: use of...

          5. 184.(1) Amend Schedule 2 (supplemental provisions as to receipts from...

        12. Finance Act 1984

          1. 185.The Finance Act 1984 is amended as follows.

          2. 186.In section 113(8) (restriction on PRT reliefs) for “section 838...

          3. 187.(1) Amend section 115 (information relating to sales at arm's...

        13. Inheritance Tax Act 1984

          1. 188.The Inheritance Tax Act 1984 is amended as follows.

          2. 189.(1) Amend section 23 (gifts to charities) as follows.

          3. 190.In section 96 (preference shares disregarded) for “section 210(4) of...

          4. 191.In section 102(1) (interpretation), in the definition of “participator”, for...

          5. 192.In Schedule 3, in the entry for “health service body”,...

        14. Police and Criminal Evidence Act 1984

          1. 193.In section 14(6) of the Police and Criminal Evidence Act...

        15. Administration of Justice Act 1985 (c. 61)

          1. 194.In paragraph 36(3) of Schedule 2 to the Administration of...

        16. Finance Act 1986

          1. 195.The Finance Act 1986 is amended as follows.

          2. 196.Minor and consequential amendments

          3. 197.In section 80B(1) (intermediaries: supplementary) for “section 839 of the...

          4. 198.In section 80D(2)(a) (repurchasers and stock lending: replacement stock on...

          5. 199.In section 88B(1) (intermediaries: supplementary) for “section 839 of the...

          6. 200.In section 89AB(2)(a) (section 87: exception for repurchasers and stock...

          7. 201.In section 90(9)(b) (section 87: other exceptions) for “section 416...

        17. Gas Act 1986

          1. 202.In section 19E(4) of the Gas Act 1986 (sections 19A...

        18. Finance Act 1987

          1. 203.The Finance Act 1987 is amended as follows.

          2. 204.In Schedule 13 (relief for research expenditure) in paragraph 11(2)...

          3. 205.In Schedule 14 (cross-field allowance) in paragraph 10(2) for “section...

        19. Local Government Finance Act 1988

          1. 206.The Local Government Finance Act 1988 is amended as follows....

          2. 207.In section 43(6)(b) (occupied hereditaments: liability) for “Schedule 18 to...

          3. 208.Minor and consequential amendments

          4. 209.In section 67(10A) (interpretation: other provisions)— (a) for “Schedule 18...

          5. 210.In paragraph 7(9) of Schedule 5 (non-domestic rating: exemption) for...

        20. Housing Act 1988

          1. 211.In section 54(2)(c) of the Housing Act 1988 (tax relief...

        21. Finance Act 1989

          1. 212.The Finance Act 1989 is amended as follows.

          2. 213.Minor and consequential amendments

          3. 214.Minor and consequential amendments

          4. 215.Omit section 102 (surrender of tax refund etc within group)....

          5. 216.In paragraph 16(2) of Schedule 5 (employee share ownership trusts)—...

          6. 217.In Schedule 12 (close companies) omit paragraphs 1, 3 and...

        22. Electricity Act 1989

          1. 218.In section 58(8) of the Electricity Act 1989 (directions restricting...

        23. Police and Criminal Evidence (Northern Ireland) Order 1989 (S.I. 1989/1341 (N.I. 12))

          1. 219.In Article 16(6) of the Police and Criminal Evidence (Northern...

        24. Finance Act 1990

          1. 220.Omit section 25(10) and (12) of the Finance Act 1990...

        25. Finance Act 1991

          1. 221.The Finance Act 1991 is amended as follows.

          2. 222.(1) Omit sections 62 to 65 (abandonment guarantees and abandonment...

          3. 223.In section 104(3) (abandonment guarantees) for “section 839 of the...

          4. 224.In section 112(7)(b) (apportionment of consideration for stamp duty purposes)...

        26. Taxation of Chargeable Gains Act 1992

          1. 225.The Taxation of Chargeable Gains Act 1992 is amended as...

          2. 226.In section 8(1) (company's total profits to include chargeable gains)...

          3. 227.In section 13(12) (attribution of gains to members of non-resident...

          4. 228.In section 37 (consideration chargeable to tax on income) after...

          5. 229.In section 39 (exclusion of expenditure by reference to tax...

          6. 230.In section 96(10) (payments by and to companies)—

          7. 231.In section 117(1) (meaning of qualifying corporate bond) for the...

          8. 232.In section 125(6) (shares in close company transferring assets at...

          9. 233.In section 125A(1) (effect of share loss relief)—

          10. 234.In section 135(4) (exchange of securities for those in another...

          11. 235.In section 140L(1)(c)(i) (interpretation) for “section 832 of the Taxes...

          12. 236.In section 151BA (CITR: identification of securities of shares on...

          13. 237.In section 151BB (CITR: rights issues etc) in subsection (5)(b)...

          14. 238.In section 151C(5) (strips) for “section 840ZA of the Taxes...

          15. 239.In section 151D(5) (corporate strips) for “section 840ZA of the...

          16. 240.In section 161 (appropriations to and from stock) after subsection...

          17. 241.In section 165A(14) (meaning of “holding company” etc), in the...

          18. 242.(1) Amend section 170 (interpretation) as follows.

          19. 243.In section 171(2)(da) (transfers within a group: general provisions) for...

          20. 244.(1) Amend section 179 (company ceasing to be a member...

          21. 245.In section 184H(5)(b) (meaning of excluded arrangements) for “section 779(1)...

          22. 246.In section 190(13) (tax recoverable from another group company or...

          23. 247.(1) Amend section 192 (tax exempt distributions) as follows.

          24. 248.In section 198(5)(b) (replacement of business assets used in connection...

          25. 249.In section 212(1)(c) (annual deemed disposal of holdings of unit...

          26. 250.After section 217C insert— Industrial and provident societies and co-operatives...

          27. 251.Minor and consequential amendments

          28. 252.In section 228 (conditions for relief: supplementary) for subsection (10)...

          29. 253.In section 239(7) (employee trusts) for “in section 417(1) of...

          30. 254.(1) Amend section 256 (charities) as follows.

          31. 255.In the title to section 256A (attributing gains to the...

          32. 256.In the title to section 256B (how gains are attributed...

          33. 257.After section 256B insert— Attributing gains to the non-exempt amount:...

          34. 258.(1) Amend section 257 (gifts to charities etc) as follows....

          35. 259.In section 263B(7) (stock lending arrangements), in the definition of...

          36. 260.In section 263E(1)(a) (structured finance arrangements) before “(disregard” insert “...

          37. 261.(1) Amend section 271 (other miscellaneous exemptions) as follows.

          38. 262.In section 276(2)(d) (the territorial sea and the continental shelf)...

          39. 263.In section 286(3A)(b) (connected persons: interpretation) for “section 840 of...

          40. 264.(1) Amend section 288 (interpretation) as follows.

          41. 265.In paragraph 7(3)(a) of Schedule 3 (assets held on 31...

          42. 266.(1) Amend Schedule 5 (attribution of gains to settlors with...

          43. 267.(1) Amend Schedule 5AA (meaning of “scheme of reconstruction”) as...

          44. 268.In paragraph 19(1) of Schedule 5B (interpretation)—

          45. 269.(1) Amend Schedule 7AC (exemptions for disposals by companies with...

        27. Finance (No.2) Act 1992(c. 48)

          1. 270.(1) The Finance (No.2) Act 1992 is amended as follows....

        28. Electricity (Northern Ireland) Order 1992 (S.I. 1992/231 (N.I. 1))

          1. 271.In Article 62(8) of the Electricity (Northern Ireland) Order 1992...

        29. Housing (Northern Ireland) Order 1992 (S.I. 1992/1725 (N.I. 15))

          1. 272.In Article 22(2)(c) of the Housing (Northern Ireland) Order 1992...

        30. Charities Act 1993

          1. 273.Minor and consequential amendments

          2. 274.Minor and consequential amendments

          3. 275.Minor and consequential amendments

        31. Finance Act 1993

          1. 276.The Finance Act 1993 is amended as follows.

          2. 277.Omit sections 92 to 92E (which set out rules about...

          3. 278.In section 193(6) (tariff receipts) for “section 839 of the...

          4. 279.In paragraph 5(1) of Schedule 20A (interpretation) in the definition...

        32. Finance Act 1994

          1. 280.The Finance Act 1994 is amended as follows.

          2. 281.In section 52A(8) (certain fees to be treated as premiums...

          3. 282.In section 219(4B) (Lloyd's underwriters: corporations etc : taxation of...

          4. 283.In section 227A(5) (restriction of group relief) for “section 402(2)...

          5. 284.In Schedule 6A (premiums liable to tax at the higher...

        33. Value Added Tax Act 1994

          1. 285.In the following provisions of the Value Added Tax Act...

        34. Finance Act 1995

          1. 286.The Finance Act 1995 is amended as follows.

          2. 287.(1) Amend section 151 (lease or tack: associated bodies) as...

          3. 288.(1) Amend section 152 (open-ended investment companies) as follows.

          4. 289.In section 154(1) (short rotation coppice) omit the words “the...

          5. 290.In paragraph 17(6)(a) of Schedule 22 (interpretation) for “section 416...

        35. Finance Act 1996

          1. 291.The Finance Act 1996 is amended as follows.

          2. 292.Omit section 175 (transactions in securities).

          3. 293.In paragraph 11(2D) of Schedule 15 (other adjustments in case...

        36. Broadcasting Act 1996

          1. 294.(1) Schedule 7 to the Broadcasting Act 1996 (transfer schemes)...

        37. Gas (Northern Ireland) Order 1996 (S.I. 1996/275 (N.I. 2))

          1. 295.(1) The Gas (Northern Ireland) Order 1996 is amended as...

        38. Finance Act 1997 (c. 16)

          1. 296.(1) Schedule 12 to the Finance Act 1997 (leasing arrangements:...

        39. Finance Act 1998

          1. 297.(1) Schedule 18 to the Finance Act 1998 (company tax...

        40. Petroleum Act 1998

          1. 298.In section 17E(7) of the Petroleum Act 1998 (section 17D:...

        41. Regional Development Agencies Act 1998

          1. 299.Minor and consequential amendments

        42. Finance Act 1999

          1. 300.The Finance Act 1999 is amended as follows.

          2. 301.In section 97 (supplementary provisions) in subsection (2)(a) for “section...

          3. 302.In section 98(7) (qualifying assets) after paragraph (a) insert—

        43. Commonwealth Development Corporation Act 1999

          1. 303.(1) Paragraph 6 of Schedule 3 to the Commonwealth Development...

        44. Greater London Authority Act 1999

          1. 304.The Greater London Authority Act 1999 is amended as follows....

          2. 305.In section 157(4) (restriction on exercise of certain powers except...

          3. 306.In section 419(2) (taxation: certain bodies treated as a local...

          4. 307.(1) Amend paragraph 13 of Schedule 33 (taxation provisions: public-private...

        45. Finance Act 2000

          1. 308.The Finance Act 2000 is amended as follows.

          2. 309.Omit section 46 (exemption for small trades etc).

          3. 310.Omit section 98 (recovery of tax payable by non-resident company)....

          4. 311.In section 119(9) (transfer of land to connected company) for...

          5. 312.In section 120(7) (exceptions) for “section 839(3) of the Taxes...

          6. 313.In section 121(8) (grant of lease to connected company) for...

          7. 314.(1) Amend Schedule 6 (climate change levy) as follows.

          8. 315.(1) Amend Schedule 15 (the corporate venturing scheme) as follows....

          9. 316.(1) Amend Schedule 22 (tonnage tax) as follows.

          10. 317.Omit Schedule 28 (recovery of tax payable by non-resident company)....

          11. 318.In Schedule 34 (supplementary provisions) in paragraph 3(4)(b) for “section...

        46. Trustee Act 2000

          1. 319.In section 19(3) of the Trustee Act 2000 (persons who...

        47. Transport Act 2000

          1. 320.The Transport Act 2000 is amended as follows.

          2. 321.(1) Amend Schedule 7 (transfer schemes: tax) as follows.

          3. 322.(1) Amend Schedule 26 (transfers: tax) as follows.

        48. Capital Allowances Act 2001

          1. 323.The Capital Allowances Act 2001 is amended as follows.

          2. 324.In section 38B (general exclusions applying to section 38A) in...

          3. 325.In section 45F(3) (expenditure on plant and machinery for use...

          4. 326.In section 56(1A) (amount of allowances and charges) for “section...

          5. 327.In section 60(1)(c) (meaning of “disposal receipt”) after “or” insert...

          6. 328.In section 63(2) (cases in which disposal value is nil)—...

          7. 329.In section 70E(2B) (disposal events and disposal values)—

          8. 330.In section 70H(1) (lessee: requirement for tax return treating lease...

          9. 331.In section 70V(4) (tax avoidance involving international leasing) for “section...

          10. 332.In section 99 (the monetary limit) for subsection (5) substitute—...

          11. 333.In section 104F(10) (special rate cars: discontinued activity continued by...

          12. 334.In section 108(1)(b)(i) (effect of disposal to connected person on...

          13. 335.In section 112(1)(b)(i) (excess allowances: connected persons) for “section 343(1)...

          14. 336.In section 115(1)(c)(i) (prohibited allowances: connected persons) for “section 343(1)...

          15. 337.In section 131(7) (effect of postponement)— (a) for “section 403ZB(2)...

          16. 338.In section 138(2)(b) (limit on amount deferred) for “section 393...

          17. 339.In section 154(3)(b)(ii) (further registration requirement) for “section 343(2) of...

          18. 340.In section 155(1)(b)(ii) (change in persons carrying on qualifying activity)...

          19. 341.In section 156(2)(b) (connected persons) for “section 343(2) of ICTA”...

          20. 342.In section 158 (members of same group) for “Chapter IV...

          21. 343.In section 162(2) (ring fence trade a separate qualifying activity)—...

          22. 344.(1) Amend section 220 (allocation of expenditure to a chargeable...

          23. 345.In section 228H(1A)(b) (sections 228A to 228G: supplementary) for “section...

          24. 346.In section 228M(2) (other definitions for the purposes of s.228K)—...

          25. 347.In section 249(2) (furnished holiday lettings business) for “Section 503...

          26. 348.In section 253(7) (companies with investment business) for “sections 768B(8)...

          27. 349.In section 260(7) (special leasing: corporation tax (excess allowance)) in...

          28. 350.In section 261 (special leasing: life assurance business) in paragraph...

          29. 351.In section 261A(3) (special leasing: leasing partnerships)—

          30. 352.In section 267A(3) (restriction on effect of election)—

          31. 353.In section 355(6) (buildings for miners etc: carry-back of balancing...

          32. 354.In section 362(2) (meaning of “husbandry”) for “section 154(3) of...

          33. 355.In section 416B(5) (expenditure incurred by company for purposes of...

          34. 356.In section 420(b) (meaning of “disposal receipt”) after “or” insert...

          35. 357.In section 476(1)(b) (disposal value of patent rights) after “or”...

          36. 358.In section 505(1) (qualifying dwelling-houses: exclusions), in paragraph (a) of...

          37. 359.After section 560 insert— Transfers of trade without a change...

          38. 360.In section 561(5) (transfer of division of UK business) for...

          39. 361.In section 561A(2) (transfer of asset by reason of cross-border...

          40. 362.In section 575A(1) (section 575: supplementary) in the definition of...

          41. 363.In section 577(1) (other definitions), in the definition of “dual...

          42. 364.(1) Amend Schedule A1 (first-year tax credits) as follows.

          43. 365.(1) Amend Schedule 1 (abbreviations and defined expressions) as follows....

        49. Finance Act 2001

          1. 366.Minor and consequential amendments

        50. Trustee Act (Northern Ireland) 2001 (c. 14 (N.I.))

          1. 367.In section 19(3) of the Trustee Act (Northern Ireland) 2001...

        51. Finance Act 2002

          1. 368.The Finance Act 2002 is amended as follows.

          2. 369.Omit section 57(1) (community investment tax relief).

          3. 370.Omit section 58 (relief for community amateur sports clubs).

          4. 371.In section 63(2)(a) (first year allowances for expenditure wholly for...

          5. 372.Minor and consequential amendments

          6. 373.Omit Schedule 16 (community investment tax relief).

          7. 374.Omit Schedule 18 (relief for community amateur sports clubs).

          8. 375.In paragraph 8(4) of Schedule 34 (stamp duty: recovery of...

          9. 376.Minor and consequential amendments

          10. 377.In Schedule 37 (supplementary provisions) in paragraph 2(4)(b) for “section...

        52. Income Tax (Earnings and Pensions) Act 2003

          1. 378.The Income Tax (Earnings and Pensions) Act 2003 is amended...

          2. 379.In section 24(6)(b) (limit on chargeable overseas earnings where duties...

          3. 380.In section 51(5) (conditions of liability where intermediary is a...

          4. 381.In section 60(1)(a) (meaning of associate) for “section 417(3) and...

          5. 382.In section 61(1) (interpretation) in the definition of “associated company”...

          6. 383.(1) Amend section 68 (meaning of “material interest” in a...

          7. 384.In section 230(4)(c) (the approved amount for mileage allowance payments)...

          8. 385.In section 357(2) (business entertainment and gifts: exception where employer's...

          9. 386.In section 421H(2) (meaning of “employee-controlled” etc) for “same meaning...

          10. 387.In section 446A(3)(b) (application of Chapter) for “section 402(6) of...

          11. 388.In section 446K(3)(b) (application of Chapter) for “section 402(6) of...

          12. 389.In section 459(3) (transfer of intellectual property by controlled company)...

          13. 390.In section 479(9)(b) (amount of gain realised on occurrence of...

          14. 391.In section 493(3) (no charge on acquisition of dividend shares)...

          15. 392.In section 538(4) (share conversions excluded for the purposes of...

          16. 393.In section 549(4)(a) (application of Chapter) for “same meaning as...

          17. 394.In section 714(2) (meaning of “donations”), in the definition of...

          18. 395.(1) Amend Schedule 1 (abbreviations and defined expressions) as follows....

          19. 396.(1) Amend Schedule 2 (approved share incentive plans) as follows....

          20. 397.(1) Amend Schedule 3 (approved SAYE option schemes) as follows....

          21. 398.(1) Amend Schedule 4 (approved CSOP schemes) as follows.

          22. 399.(1) Amend Schedule 5 (enterprise management incentives) as follows.

        53. Finance Act 2003

          1. 400.The Finance Act 2003 is amended as follows.

          2. 401.In section 44(11) (contract and conveyance) for “Section 839 of...

          3. 402.In section 45(6) (contract and conveyance: effect of transfer of...

          4. 403.In section 45A(10) (contract providing for conveyance to third party:...

          5. 404.In section 53(2) (deemed market value where transaction involves connected...

          6. 405.In section 54(3)(b) (exceptions from deemed market value rule) for...

          7. 406.In section 73AB(4) (sections 71A to 72A: arrangements to transfer...

          8. 407.In section 75A(5)(b) (anti-avoidance) for “section 839 of the Taxes...

          9. 408.In section 101(6) (unit trust schemes) for “Section 469A of...

          10. 409.In section 108(1) (linked transactions) for “Section 839 of the...

          11. 410.Omit section 148 (meaning of “permanent establishment”).

          12. 411.Omit section 150 (non-resident companies: assessment, collection and recovery of...

          13. 412.Omit section 152 (non-resident companies: transactions carried out through broker,...

          14. 413.(1) Amend section 195 (companies acquiring their own shares) as...

          15. 414.In Schedule 4 (stamp duty land tax: chargeable consideration) in...

          16. 415.In Schedule 6A (relief for certain acquisitions of residential property)...

          17. 416.(1) Amend Schedule 7 (stamp duty land tax: group relief...

          18. 417.(1) Amend Schedule 9 (stamp duty land tax: right to...

          19. 418.(1) Amend Schedule 15 (stamp duty land tax: partnerships) as...

          20. 419.In Schedule 17A (further provisions relating to leases) in paragraph...

          21. 420.In Schedule 20 (stamp duty: restriction to instruments relating to...

          22. 421.Omit Schedule 26 (non-resident companies: transactions through broker, investment manager...

        54. Housing (Northern Ireland) Order 2003 (S.I. 2003/412 (N.I. 2))

          1. 422.In Article 85(2) of the Housing (Northern Ireland) Order 2003...

        55. Finance Act 2004

          1. 423.The Finance Act 2004 is amended as follows.

          2. 424.Omit section 50 (generally accepted accounting practice).

          3. 425.Omit section 51 (use of different accounting practices within a...

          4. 426.In section 59(4) (contractors) for “section 343 of the Taxes...

          5. 427.Omit section 83 (giving through the self-assessment return).

          6. 428.In section 273(9) (members liable as scheme administrator) for “section...

          7. 429.In section 307(2)(b) (meaning of “promoter”)— (a) for “section 840A...

          8. 430.In paragraph 4(2) of Schedule 11 (the compliance test) for...

          9. 431.(1) Amend Schedule 29A (taxable property held by investment-regulated pension...

          10. 432.(1) Amend Schedule 36 (pension schemes: transitional provision and savings)...

        56. Energy Act 2004

          1. 433.The Energy Act 2004 is amended as follows.

          2. 434.(1) Amend section 27 (tax exemption for NDA activities) as...

          3. 435.(1) Amend section 28 (taxation of activities of the Nuclear...

          4. 436.In section 44(2) (extinguishment of BNFL losses for tax purposes)—...

          5. 437.In paragraph 3 of Schedule 4 (supplemental taxation provisions for...

          6. 438.(1) Amend Schedule 9 (taxation provisions relating to nuclear transfer...

        57. Companies (Audit, Investigations and Community Enterprise) Act 2004

          1. 439.(1) Section 54C of the Companies (Audit, Investigations and Community...

        58. Scotland Act 1998 (Transfer of Functions to the Scottish Ministers etc) Order 2004 (S.I. 2004/2030)

          1. 440.The Scotland Act 1998 (Transfer of Functions to the Scottish...

          2. 441.Omit article 3 (transfer of functions to the Scottish Ministers)....

          3. 442.Omit article 5 (modification of ICTA).

          4. 443.In article 6 (general modifications of enactments etc)—

        59. Income Tax (Trading and Other Income) Act 2005

          1. 444.The Income Tax (Trading and Other Income) Act 2005 is...

          2. 445.In section 100(4) (meaning of sale and lease-back arrangement) for...

          3. 446.In section 108(3) (gifts of trading stock to charities etc)...

          4. 447.For section 148D (lessor under long funding operating lease: periodic...

          5. 448.After section 148D insert— Starting value”: general (1) This section is about the meaning of “starting value”...

          6. 449.For section 148E substitute— Long funding operating lease: lessor's additional...

          7. 450.After section 148E insert— Determination of remaining residual value resulting...

          8. 451.For section 148F substitute— Lessor under long funding operating lease:...

          9. 452.In section 375(1) (interpretation of sections 373 and 374) for...

          10. 453.In section 388(1) (interpretation of sections 386 and 387) for...

          11. 454.In section 389(5) (authorised unit trust dividend distributions) for “section...

          12. 455.In section 401(7) (relief: qualifying distributions after linked non-qualifying distribution)...

          13. 456.In Chapter 3 of Part 4 after section 401 insert—...

          14. 457.After section 401A insert— Power to obtain information (1) An officer of Revenue and Customs may, for the...

          15. 458.(1) Amend section 410 as follows. (2) For subsection (1)...

          16. 459.After section 410 insert— Conversion etc of bonus share capital...

          17. 460.(1) Amend section 412 (cash equivalent of share capital) as...

          18. 461.After section 414 insert— Interpretation of Chapter (1) In this Chapter “bonus share capital” means—

          19. 462.(1) Amend section 415 (charge to tax under Chapter 6)...

          20. 463.In section 419(1)(b) (loans and advances to people who die)...

          21. 464.In section 420(1)(b) (loans and advances to trustees of settlements...

          22. 465.After section 421 insert— Power to obtain information (1) An officer of Revenue and Customs may, for the...

          23. 466.(1) Amend section 456 (securities issued to connected persons etc...

          24. 467.In section 460(2) (minor definitions) for “section 840ZA of ICTA”...

          25. 468.In section 482(7) (conditions in relation to excepted group life...

          26. 469.In section 520(4) (the property categories) for “section 842 of...

          27. 470.In section 643(4) (interpretation) for “section 416 of ICTA” substitute...

          28. 471.(1) Amend Schedule 2 (transitionals and savings) as follows.

          29. 472.(1) Amend Schedule 4 (abbreviations and defined expressions) as follows....

        60. Finance Act 2005

          1. 473.The Finance Act 2005 is amended as follows.

          2. 474.(1) In section 48B(5) (alternative finance arrangements: alternative finance investment...

          3. 475.(1) Omit section 54A (treatment of section 47, 49 and...

          4. 476.Omit section 84 (taxation of securitisation companies).

          5. 477.In section 102(7)(b) (Pension Protection Fund etc) for “section 832(1)...

        61. Railways Act 2005

          1. 478.(1) Schedule 10 to the Railways Act 2005 (taxation provisions...

        62. Finance (No. 2) Act 2005 (c. 22)

          1. 479.In section 17(4) of the Finance (No. 2) Act 2005...

        63. Finance Act 2006

          1. 480.The Finance Act 2006 is amended as follows.

          2. 481.Omit section 82 (sale etc of lessor companies etc).

          3. 482.In section 83(6)(a) (restrictions on use of losses etc: leasing...

          4. 483.In Part 4 (Real Estate Investment Trusts) omit—

          5. 484.Omit Schedule 10 (sale etc of lessor companies etc).

          6. 485.Omit Schedule 16 (Real Estate Investment Trusts: excluded business and...

          7. 486.Omit Schedule 17 (group Real Estate Investment Trusts: modifications).

        64. Companies Act 2006

          1. 487.The Companies Act 2006 is amended as follows.

          2. 488.In section 141(4)(a) (subsidiary acting as authorised dealer in securities)...

          3. 489.Minor and consequential amendments

          4. 490.In section 1278(1)(c) (institutions to which information provisions apply) for...

        65. Charities Act 2006 (c. 50)

          1. 491.Minor and consequential amendments

          2. 492.Minor and consequential amendments

          3. 493.Minor and consequential amendments

        66. Income Tax Act 2007

          1. 494.The Income Tax Act 2007 is amended as follows.

          2. 495.In section 69(7) (whether trade is same trade) for “has...

          3. 496.In section 136(2) (disposals of new shares) for “one of...

          4. 497.In section 139(4) (the control and independence requirement) in the...

          5. 498.(1) Amend section 151 (interpretation of Chapter) as follows.

          6. 499.In section 170 (persons interested in capital etc of company)—...

          7. 500.In section 190 (meaning of “qualifying 90% subsidiary”)—

          8. 501.In section 199(3)(c) (excluded activities: provision of services or facilities...

          9. 502.In section 232(4)(a) (acquisition of a trade or trading assets)—...

          10. 503.In section 257 (minor definitions)— (a) in subsection (1) in...

          11. 504.In section 301 (meaning of “qualifying 90% subsidiary”)—

          12. 505.In section 310(3)(c) (excluded activities: provision of services or facilities...

          13. 506.In section 313 (interpretation)— (a) in subsection (4) for “section...

          14. 507.In section 332 (minor definitions etc) in the definition of...

          15. 508.In section 340 (application and criteria for accreditation) after subsection...

          16. 509.In section 341 (terms and conditions of accreditation) after subsection...

          17. 510.In section 346 (conditions to be met in relation to...

          18. 511.(1) Amend section 348 (CITR: tax relief certificates) as follows....

          19. 512.In section 355 (securities or shares: no claim after disposal...

          20. 513.(1) Amend section 356 (no claim after loss of accreditation...

          21. 514.(1) Amend section 361 (disposal of securities or shares during...

          22. 515.In section 363 (value received by investor during 6 year...

          23. 516.In section 364 (value received by investor during 6 year...

          24. 517.In section 365 (receipts of insignificant value to be added...

          25. 518.In section 368 (value received if more than one investment)...

          26. 519.In section 369 (effect of receipt of value on future...

          27. 520.In section 373 (information to be provided by the investor)...

          28. 521.In section 392(4) (loan to buy interest in close company)—...

          29. 522.In section 394(5) (meaning of “material interest” in section 393)—...

          30. 523.In section 395(6) (meaning of “associate” in section 394) in...

          31. 524.In section 413(5) (overview of Chapter) for the words from...

          32. 525.In section 426(7) (election by donor: gift treated as made...

          33. 526.In section 430(1)(d) (“charity” to include exempted bodies) for “Schedule...

          34. 527.In section 432(2) (meaning of “qualifying investment”), in the definition...

          35. 528.In section 442(7)(b) (qualifying interests in land held jointly) for...

          36. 529.In section 443(5) (calculation of relievable amount where joint disposal...

          37. 530.In section 527(2)(a) for “section 214 of ICTA” substitute “...

          38. 531.In section 531(2A) (exemption for property income etc) for “section...

          39. 532.Minor and consequential amendments

          40. 533.Minor and consequential amendments

          41. 534.Minor and consequential amendments

          42. 535.Minor and consequential amendments

          43. 536.In section 559(3) (securities which are approved charitable investments), in...

          44. 537.In section 576 (manufactured dividends on UK shares: Real Estate...

          45. 538.(1) Amend section 577 (statements about manufactured dividends) as follows....

          46. 539.In section 591(1) (interpretation of other terms used in Chapter)—...

          47. 540.In section 597(1)(d) (deemed interest: cash collateral under stock lending...

          48. 541.(1) Amend section 602 (deemed manufactured payments: repos) as follows....

          49. 542.(1) Amend section 603 (deemed deductions of tax) as follows....

          50. 543.(1) Amend section 604 (deemed increase in repurchase price: price...

          51. 544.In section 606 (interpretation of Chapter)— (a) for subsection (2)...

          52. 545.Minor and consequential amendments

          53. 546.Minor and consequential amendments

          54. 547.In section 772(1) (interpretation of Chapter) for “section 776 of...

          55. 548.In section 809ZA (plant and machinery leases: capital receipts to...

          56. 549.Omit section 809ZB (section 809ZA: interpretation).

          57. 550.In section 809ZC(1) (section 809ZA: lease of plant and machinery...

          58. 551.After section 809ZD insert— Capital payment”, “relevant capital payment” etc...

          59. 552.In section 809M(3) (meaning of “relevant person”)—

          60. 553.In section 836(3) (jointly held property) for “section 254 of...

          61. 554.In section 899(5) (meaning of “qualifying annual payment”) for paragraph...

          62. 555.In section 918 (manufactured dividends on UK shares: Real Estate...

          63. 556.(1) Amend section 928 (chargeable payments connected with exempt distributions)...

          64. 557.In section 936(2) (recipients who are to be paid gross)—...

          65. 558.In section 953(6) (how a set-off claim works)—

          66. 559.In section 972(6) (regulations under section 971) for “section 121(2)(c)...

          67. 560.(1) Amend section 973 (income tax due in respect of...

          68. 561.(1) Amend section 974 (regulations under section 973) as follows....

          69. 562.(1) Amend section 989 (definitions) as follows.

          70. 563.In section 991 (meaning of “bank”) after subsection (4) insert—...

          71. 564.In section 992(2) (meaning of “company”) for “section 468 of...

          72. 565.In section 994(1) (meaning of “connected” person: supplementary) in the...

          73. 566.In section 997(5) (meaning of “international accounting standards”) for “section...

          74. 567.(1) Amend section 999 (meaning of “local authority”) as follows....

          75. 568.In section 1000 (meaning of “local authority association”) for subsections...

          76. 569.In section 1016(2) (table of provisions to which that section...

          77. 570.In section 1017 (abbreviated references to Acts) at the appropriate...

          78. 571.(1) Amend Schedule 2 (transitional and savings) as follows.

          79. 572.In Schedule 4 (index of defined expressions)—

        67. Finance Act 2007

          1. 573.The Finance Act 2007 is amended as follows.

          2. 574.Omit section 3 (small companies' rates and fractions for financial...

          3. 575.In paragraph 5(4)(b) of Schedule 24 (potential lost revenue: normal...

        68. Finance Act 2008

          1. 576.The Finance Act 2008 is amended as follows.

          2. 577.In section 6(3) (charge and main rates for financial year...

          3. 578.Omit section 7 (small companies' rates and fractions for financial...

          4. 579.In section 165(1) (interpretation) at the appropriate place insert— “CTA...

          5. 580.(1) Amend Schedule 19 (reduction of basic rate of income...

          6. 581.(1) Amend Schedule 20 (leases of plant or machinery) as...

          7. 582.(1) Amend Schedule 36 (information and inspection powers) as follows....

          8. 583.In paragraph 7(4) of Schedule 41 (potential lost revenue)—

        69. Crossrail Act 2008 (c. 18)

          1. 584.(1) Schedule 13 to the Crossrail Act 2008 (transfer schemes:...

        70. Charities Act (Northern Ireland) 2008 (c. 12 (N.I.))

          1. 585.The Charities Act (Northern Ireland) 2008 is amended as follows....

          2. 586.In section 5(4) for the words from “a club” to...

          3. 587.(1) Amend section 45 as follows. (2) In subsection (1)—...

        71. Transfer of Housing Corporation Functions (Modifications and Transitional Provisions) Order 2008 (S.I. 2008/2839)

          1. 588.In paragraph 1 of the Schedule to the Transfer of...

        72. Corporation Tax Act 2009 (c. 4)

          1. 589.The Corporation Tax Act 2009 is amended as follows.

          2. 590.In section 20(3) (profits attributable to permanent establishment: introduction) for...

          3. 591.In section 25(3) (non-UK resident banks: introduction) for “section 840A...

          4. 592.In section 39(3) (profits of mines, quarries and other concerns)...

          5. 593.In section 57 (car hire: supplementary)— (a) in subsection (2)(a)...

          6. 594.In section 87(5) (expenses of research and development) for “section...

          7. 595.In section 88(1)(a) (payments to research associations, universities etc)—

          8. 596.In section 97(4) (meaning of sale and lease-back arrangement) for...

          9. 597.(1) Amend section 105 (gifts of trading stock to charities...

          10. 598.In section 132(5) (dividends etc granted by industrial and provident...

          11. 599.In section 168 (connected persons) in paragraph (a) for “section...

          12. 600.After section 221 insert— Sums to which sections 217 to...

          13. 601.In section 260(3) (mutual business) for “section 488 of ICTA”...

          14. 602.In section 264(2) (overview of Chapter) for paragraph (a) substitute—...

          15. 603.In section 269(2)(b) (capital allowances and loss relief) for “Chapter...

          16. 604.In section 297(5)(c) (trading credits and debits to be brought...

          17. 605.In section 326(3) (writing off government investments)—

          18. 606.In section 345(1)(b) (transferee leaving group otherwise than because of...

          19. 607.In section 346(1) (transferee leaving group because of exempt distribution)—...

          20. 608.In section 364(5) (introduction to Chapter) for “section 403C of...

          21. 609.(1) Amend section 371 (interpretation) as follows.

          22. 610.(1) Amend section 376 (interpretation of section 375) as follows....

          23. 611.In section 383(8) (lending between partners and the partnership) for...

          24. 612.(1) Amend section 390 (meaning of available profits) as follows....

          25. 613.In section 410(5) (exception to section 409) in the definition...

          26. 614.In section 411(3) (interpretation of section 409)—

          27. 615.Minor and consequential amendments

          28. 616.(1) Amend section 443 (restriction of relief for interest where...

          29. 617.In section 448(1)(c) (exchange gains and losses on debtor relationships:...

          30. 618.(1) Amend section 457 (basic rule for deficits: carry forward...

          31. 619.In section 459(2) (claim to set off deficit against profits...

          32. 620.(1) Amend section 461 (claim to set off deficit against...

          33. 621.In section 463(5) (profits available for relief under section 462)—...

          34. 622.In section 464(3) (priority of Part for corporation tax purposes)—...

          35. 623.In section 465(3) (exclusion of distributions except in tax avoidance...

          36. 624.In section 476(1) (other definitions)— (a) in the definition of...

          37. 625.In section 486F(2)(a) (meaning of “income stream transfer”) for “Part...

          38. 626.In section 486G(2) (meaning of “relevant receipts”) for “paragraph 1(2)...

          39. 627.(1) Amend section 488 (meaning of “open-ended investment company etc”)...

          40. 628.(1) Amend section 493 (the qualifying investments test) as follows....

          41. 629.In section 495(3)(a)(ii) (qualifying holdings) for “section 468A(3) of ICTA”...

          42. 630.In section 502(1)(a) (meaning of “financial institution”) for “section 840A...

          43. 631.In section 518(2)(c) (investment bond arrangements: treatment as securities) for...

          44. 632.(1) Amend section 519 (investment bond arrangements: other provisions) as...

          45. 633.In section 520(2)(b) (provision not at arm's length: non-deductibility of...

          46. 634.In section 521D(5) (excepted shares) for the words from “Chapter...

          47. 635.In section 539(7) (introduction to Chapter 9 of Part 6)...

          48. 636.In section 540(3) (manufactured interest treated as interest under loan...

          49. 637.(1) Amend section 541 (debits for deemed interest under stock...

          50. 638.In section 606H(11) (other interpretative provisions) for “section 840ZA of...

          51. 639.In section 629(5) (tax avoidance), in the definition of “tax...

          52. 640.In section 631(1) (transferee leaving group otherwise than because of...

          53. 641.In section 632(1) (transferee leaving group because of exempt distribution)—...

          54. 642.In section 691(6) (meaning of “unallowable purpose”) for “section 840ZA...

          55. 643.(1) Amend section 710 (other definitions) as follows.

          56. 644.In section 753(3)(b) (treatment of non-trading losses) for “(see section...

          57. 645.In section 768 (company cannot be member of more than...

          58. 646.In section 772 (equity holders and profits or assets available...

          59. 647.In section 773(1) (supplementary provisions) for “section 838 of ICTA”...

          60. 648.In section 775(4)(b) (transfers within a group) for “section 404...

          61. 649.In section 777(3)(e) (relief on realisation and reinvestment: application to...

          62. 650.In section 784 (groups with a relevant connection) for subsection...

          63. 651.In section 787(5) (company ceasing to be member of group...

          64. 652.In section 793(4)(b) (further requirements about elections) for “section 404...

          65. 653.(1) Amend section 796 (interpretation of section 795) as follows....

          66. 654.In section 814(5) (research and development) for “section 837A of...

          67. 655.In section 818(4)(b) (company reconstruction involving transfer of business) for...

          68. 656.In section 826(3)(c) (amalgamation of, or transfer of engagements by,...

          69. 657.(1) Amend section 841 (“participator” and “associate”) as follows.

          70. 658.In section 847(5)(a) (transfers involving other taxes) for “section 209...

          71. 659.In section 931B(b) (exemption of distributions received by small companies)...

          72. 660.In section 931D(b) (exemption of distributions received by companies that...

          73. 661.In section 931V(2) (meaning of “scheme” and “tax advantage scheme”)...

          74. 662.Omit section 968 (meaning of “personal representatives”) (including the italic...

          75. 663.In section 971(2)(b) (overview of Chapter) for “section 7(2) of...

          76. 664.In section 974(6) (charge to tax under Chapter 6) for...

          77. 665.In section 1004(9) (groups, consortiums and commercial associations of companies)...

          78. 666.In section 1041 (“research and development”) for “section 837A of...

          79. 667.(1) Amend section 1048 (treatment of deemed trading loss under...

          80. 668.In section 1049(3) (restriction on consortium relief) for “under section...

          81. 669.(1) Amend section 1056 (amount of unrelieved trading loss) as...

          82. 670.In section 1062(2) (restriction on losses carried forward where tax...

          83. 671.. . . . . . . . . ....

          84. 672.Minor and consequential amendments

          85. 673.Minor and consequential amendments

          86. 674.Minor and consequential amendments

          87. 675.In section 1116(4)(a) (meaning of “the actual reduction in tax...

          88. 676.In section 1142(1) (meaning of “qualifying body”)—

          89. 677.(1) Amend section 1153 (amount of unrelieved loss) as follows....

          90. 678.(1) Amend section 1158 (restriction on losses carried forward where...

          91. 679.In section 1179 (other definitions) for the definition of “UK...

          92. 680.In section 1209(2) (restriction on use of losses while film...

          93. 681.(1) Amend section 1210 (use of losses in later periods)...

          94. 682.(1) Amend section 1211 (terminal losses) as follows.

          95. 683.In section 1219 (expenses of management of a company's investment...

          96. 684.In section 1220(5)(b) (meaning of “unallowable purpose”) for “section 840ZA...

          97. 685.In section 1221(1) (amounts treated as expenses of management)—

          98. 686.(1) Amend section 1223 (carrying forward expenses of management and...

          99. 687.In section 1225(3) (accounts conforming with GAAP) for “section 1311”...

          100. 688.In section 1229(6) (claw back of relief) for “section 1311”...

          101. 689.In section 1248 (expenses in connection with arrangements for securing...

          102. 690.In section 1256(2) (overview) for “section 116 of ICTA (arrangements...

          103. 691.(1) Amend section 1262 (allocation of firm's profits or losses...

          104. 692.Before section 1302 insert— Qualifying charitable donations In calculating a company's income from any source for corporation...

          105. 693.In section 1306(3)(a) (losses calculated on same basis as miscellaneous...

          106. 694.(1) Amend section 1307 (apportionment etc of miscellaneous profits and...

          107. 695.In section 1308(7) (expenditure brought into account in determining value...

          108. 696.Omit section 1311 (apportionment to different periods) (including the italic...

          109. 697.In section 1312 (abbreviated references to Acts) insert at the...

          110. 698.(1) Amend section 1316 (meaning of “connected” persons and “control”)...

          111. 699.Omit section 1317 (meaning of “farming” and related expressions).

          112. 700.Omit section 1318 (meaning of grossing up).

          113. 701.(1) Amend section 1319 (other definitions) as follows.

          114. 702.Omit section 1320(1) (interpretation: Scotland).

          115. 703.(1) Amend Schedule 2 (transitionals and savings) as follows.

          116. 704.(1) Amend Schedule 4 (index of defined expressions) as follows....

        73. Saving Gateway Accounts Act 2009 (c. 8)

          1. 705.Minor and consequential amendments

        74. Finance Act 2009 (c. 10)

          1. 706.The Finance Act 2009 is amended as follows.

          2. 707.In section 7(3) (charge and main rates for financial year...

          3. 708.In section 8(4) (small companies' rates and fractions for financial...

          4. 709.Omit section 38 (corporation tax: foreign currency accounting).

          5. 710.In section 45(6) (power to enable dividends of investment trusts...

          6. 711.Omit section 90 (supplementary charge: reduction for certain new oil...

          7. 712.In section 126(1) (interpretation) at the appropriate place insert— “CTA...

          8. 713.In Schedule 3 (VAT: supplementary charge and orders changing rate)...

          9. 714.(1) Amend paragraph 3 of Schedule 6 (temporary extension of...

          10. 715.Omit Schedule 18 (corporation tax: foreign currency accounting).

          11. 716.(1) Amend Schedule 22 (offshore funds) as follows.

          12. 717.Omit paragraphs 1 to 6 of Schedule 25 (transfer of...

          13. 718.(1) Amend Schedule 33 (long funding leases of films) as...

          14. 719.In Schedule 35 (pensions: special annual allowance charge) in paragraph...

          15. 720.Omit Schedule 44 (supplementary charge: reduction for certain new oil...

          16. 721.(1) Amend paragraph 18 of Schedule 46 (duties of senior...

          17. 722.In Schedule 53 (late payment interest) in paragraph 6 for...

          18. 723.In Schedule 55 (penalty for failure to make returns etc)...

          19. 724.(1) Amend Schedule 61 (alternative finance investment bonds) as follows....

    2. SCHEDULE 2

      Transitionals and savings etc

      1. Part 1 General provisions

        1. Continuity of the law: general

          1. 1.The repeal of provisions and their enactment in a rewritten...

          2. 2.Paragraph 1 does not apply to any change made by...

          3. 3.Any subordinate legislation or other thing which—

          4. 4.(1) Any reference (express or implied) in this Act, another...

          5. 5.(1) Any reference (express or implied) in any enactment, instrument...

          6. 6.Paragraphs 1 to 5 have effect instead of section 17(2)...

          7. 7.Paragraphs 4 and 5 apply only so far as the...

        2. General saving for old transitional provisions and savings

          1. 8.(1) The repeal by this Act of a transitional or...

        3. Interpretation

          1. 9.(1) In this Part— “enactment” includes subordinate legislation (within the...

      2. Part 2 Changes in the law

        1. 10.(1) This paragraph applies if, in the case of any...

      3. Part 3 Currency

        1. Sterling equivalent of certain losses carried back to an earlier period

          1. 11.(1) This paragraph applies if— (a) a loss of a...

        2. Adjustment of certain sterling losses carried back to an earlier period

          1. 12.(1) This paragraph applies if— (a) a loss arises in...

        3. Right of company to elect for alternative provision to apply

          1. 13.(1) Paragraphs 14, 15 and 16 apply if a company—...

          2. 14.In relation to an accounting period beginning before 21 July...

          3. 15.This Schedule has effect in relation to the company as...

          4. 16.In relation to profits or losses arising in accounting periods...

      4. Part 4 Loss relief (other than share loss relief)

        1. Carry forward loss reliefs

          1. 17.(1) The repeal by this Act of the superseded carry...

        2. Trade loss relief against total profits

          1. 18.(1) This paragraph applies for the purposes of section 37...

          2. 19.(1) This paragraph applies for the purposes of section 42...

        3. Transfers of trade to obtain relief

          1. 20.Section 41 does not have effect in relation to cessations...

        4. Dealings in commodity futures

          1. 21.Section 52(1)(c) does not cover arrangements made wholly before 6...

        5. Leasing contracts and company reconstructions

          1. 22.Section 53(1)(a) does not cover contracts entered into before 6...

        6. Reliefs for limited partners not to exceed contribution to the firm

          1. 23.The relief covered by section 56(4) includes—

        7. Reliefs for members of LLPs not to exceed contribution to the LLP

          1. 24.(1) The relief covered by section 59(4) includes relief given...

        8. Loss relief against miscellaneous income: Case VI losses under ICTA

          1. 25.(1) This paragraph applies to any loss made by a...

        9. Write-off of government investment

          1. 26.Section 92(1) does not cover government investment written off before...

      5. Part 5 Losses on disposal of shares

        1. Disposals of new shares

          1. 27.(1) In relation to new shares issued before 1 April...

        2. Qualifying trading companies

          1. 28.(1) In relation to shares issued before 17 March 2004,...

        3. The trading requirement

          1. 29.(1) In relation to shares issued before 6 April 2007,...

        4. Ceasing to meet trading requirement because of administration or receivership

          1. 30.(1) In relation to shares issued before 17 March 2004,...

        5. The control and independence requirement

          1. 31.(1) In relation to shares issued before 6 April 2007,...

        6. The qualifying subsidiaries requirement

          1. 32.Section 82 does not apply in relation to shares issued...

        7. The property managing subsidiaries requirement

          1. 33.Section 83 does not apply in relation to shares issued...

        8. The gross assets requirement

          1. 34.(1) In relation to shares issued before 6 April 2006,...

        9. The unquoted status requirement

          1. 35.(1) In relation to shares issued before 7 March 2001,...

        10. Power to amend requirements by Treasury order

          1. 36.Section 86 does not apply in relation to shares issued...

        11. Relief after an exchange of shares for shares in another company

          1. 37.(1) In relation to new shares issued before 1 April...

        12. substitution of new shares for old shares

          1. 38.Section 88 does not apply in relation to shares issued...

        13. Interpretation of Chapter

          1. 39.(1) In relation to shares issued before 1 April 2010,...

          2. 40.In relation to shares issued before 6 April 1998, section...

        14. Meaning of “qualifying 90% subsidiary”

          1. 41.(1) This paragraph applies in relation to shares issued before...

        15. Meaning of “qualifying subsidiary”

          1. 42.In relation to shares issued before 17 March 2004, section...

        16. Meaning of “excluded activities”

          1. 43.(1) In relation to shares issued before 6 April 2008,...

        17. Excluded activities: wholesale and retail distribution

          1. 44.In relation to shares issued before 6 April 2007, section...

        18. Excluded activities: leasing of ships

          1. 45.(1) In relation to shares issued before 6 April 2007,...

        19. Excluded activities: receipt of royalties and licence fees

          1. 46.(1) Sub-paragraph (3) applies, in the circumstances mentioned in sub-paragraph...

          2. 47.(1) This paragraph applies in relation to shares issued on...

          3. 48.In relation to shares issued before 6 April 2000, section...

        20. Excluded activities: provision of services or facilities for another business

          1. 49.In relation to shares issued before 6 April 2007, section...

        21. Meaning of a company being “in administration”

          1. 50.(1) Sub-paragraph (2) applies in relation to—

        22. Application in relation to corresponding bonus shares

          1. 51.(1) For the purposes of this Part of this Schedule,...

      6. Part 6 Group Relief

        1. 52.In section 127 “arrangements” covers only— (a) arrangements made on...

        2. 53.Section 175 has effect in relation to an accounting period...

        3. 54.Sections 173 to 178 do not have effect where the...

        4. 55.(1) Sub-paragraph (2) applies in relation to shares issued by...

      7. Part 7 Charitable donations relief

        1. Condition as to repayment

          1. 56.Section 192, and the words “(but see section 192)” in...

        2. Restrictions on associated benefits

          1. 57.(1) This paragraph applies if— (a) a payment is made...

        3. Enactment of extra-statutory concession

          1. 58.(1) This paragraph applies if the Enactment of Extra-Statutory Concessions...

      8. Part 8 CITR

        1. 59.(1) Sub-paragraph (2) applies in relation to any time after...

      9. Part 9 Oil activities

        1. Regional development grants

          1. 60.In relation to accounting periods beginning before 1 April 2011—...

      10. Part 10 Leasing plant or machinery

        1. Disapplication of Chapter 2 of Part 9

          1. 61.(1) Chapter 2 of Part 9 (long funding leases of...

        2. Disapplication of sections 360 and 361 and modification of section 360 in some cases

          1. 62.(1) If at the beginning of 13 December 2007—

        3. Disapplication of provisions about cases where sections 360 to 369 do not apply

          1. 63.(1) Sections 370 and 371 do not apply if—

          2. 64.(1) Section 376 (films) does not apply if the inception...

        4. Relief for expenses otherwise carried forward: losses incurred in accounting periods ending before 22 April 2009

          1. 65.(1) In relation to losses incurred in accounting periods ending...

          2. 66.(1) In relation to losses incurred in accounting periods ending...

          3. 67.(1) In relation to losses incurred in accounting periods ending...

        5. Modifications of sales of lessors Chapters in Part 9 where the relevant date is before 22 April 2009

          1. 68.(1) If the relevant date for the purposes of any...

      11. Part 11 Close companies

        1. Exceptions to the charge under section 455

          1. 69.(1) The reference in section 456(4)(b) to other outstanding loans...

      12. Part 12 Charitable companies etc

        1. Transactions in deposits

          1. 70.The repeal by this Act of section 56(3)(c) of ICTA...

        2. Exemption for investment income

          1. 71.In relation to distributions paid before 1 July 2009 section...

        3. Exemption for certain miscellaneous income

          1. 72.(1) In relation to distributions paid before 1 July 2009...

        4. Transactions with substantial donors

          1. 73.Section 496(1)(e) and (f) and sections 502 to 510 (non-charitable...

          2. 74.For the purposes of section 502 a person may meet...

          3. 75.In relation to times before 23 April 2009, section 502(2)(b)...

          4. 76.Until paragraph 15 of Schedule 9 to the Housing and...

        5. Non-charitable expenditure

          1. 77.(1) This paragraph applies if, as a result of sections...

      13. Part 13 Real Estate Investment Trusts

        1. Notice under section 523 or 524

          1. 78.(1) This paragraph applies in relation to accounting periods beginning...

        2. Property rental business: excluded business

          1. 79.(1) In relation to any time before 6 July 2009,...

      14. Part 14 Co-operative housing associations and self-build societies

        1. Concurrent exercise of functions

          1. 80.So far as any function of the Welsh Ministers under...

          2. 81.So far as any function of the Welsh Ministers under...

        2. Delegation of functions to the Regulator of Social Housing

          1. 82.Until paragraph 13 of Schedule 9 to the Housing and...

          2. 83.Until paragraph 14 of Schedule 9 to the Housing and...

      15. Part 15 Transactions in securities

        1. Transactions in securities: general

          1. 84.(1) Part 15 (transactions in securities), so far as relating...

        2. Transactions in securities: meaning of relevant companies for the purposes of sections 737 and 738

          1. 85.(1) In its application to a transaction in securities that...

      16. Part 16 Factoring of income etc

        1. Transfers of income streams

          1. 86.Chapter 1 of Part 16 does not have effect in...

        2. Application of Chapter 2 of Part 16 (finance arrangements) to pre-6 June 2006 arrangements

          1. 87.Chapter 2 of Part 16 has no effect in relation...

        3. Application of section 771 (finance arrangements: exceptions)

          1. 88.(1) In relation to a transfer before 22 April 2009,...

        4. Application of section 779 (income-transfer under loan or credit transaction)

          1. 89.In relation to a transfer before 22 April 2009, section...

      17. Part 17 Manufactured payments and repos

        1. Manufactured dividends and manufactured overseas dividends: distributions paid before 1 July 2009

          1. 90.Manufactured payments and repos

          2. 91.Manufactured payments and repos

        2. Manufactured overseas dividends: overseas dividends paid before 22 April 2009

          1. 92.Manufactured payments and repos

        3. Deemed manufactured payments: stock lending arrangements

          1. 93.Manufactured payments and repos

          2. 94.Manufactured payments and repos

      18. Part 18 Sale and lease-back etc

        1. New lease of land after assignment or surrender: right to new lease existed pre-22 June 1971

          1. 95.(1) Sub-paragraphs (2) and (3) apply if—

      19. Part 19 Tax avoidance involving leasing plant or machinery

        1. Relevant capital payments: pre-12 March 2008 payments and obligations

          1. 96.(1) Chapter 2 of Part 20 does not apply as...

        2. Relevant capital payments: leases whose inception is before 22 April 2009

          1. 97.(1) In relation to payments made under leases whose inception...

      20. Part 20 Leasing arrangements: finance leases and loans

        1. Old bad debts

          1. 98.So far as it applies in relation to a period...

      21. Part 21 Transfers of trade without a change in ownership

        1. 99.Section 945 does not apply if the transfer of the...

        2. 100.Section 949 does not apply if the transfer of the...

      22. Part 22 Use of different accounting practices within a group

        1. 101.Section 996 does not have effect in relation to periods...

      23. Part 23 Company distributions

        1. Amount of principal secured: non-commercial securities

          1. 102.Section 1006 applies only to securities issued after 5 April...

        2. Meaning of “special securities”

          1. 103.(1) Securities do not meet Condition A in section 1015...

        3. Amount of principal secured: special securities

          1. 104.Section 1018(1) applies only to securities issued after 5 April...

        4. Bonus issue following repayment of share capital

          1. 105.(1) Section 1022(3) (amount paid up on bonus share capital...

        5. Share capital issued as paid up otherwise than by receipt of new consideration

          1. 106.(1) In relation to share capital issued before 7 April...

        6. Interest etc paid in respect of certain securities

          1. 107.(1) Section 1032(1) does not apply in the case of...

        7. Stock dividends

          1. 108.(1) This paragraph applies if— (a) share capital is issued...

          2. 109.Section 1050 does not apply in relation to a conversion...

        8. Exempt distributions

          1. 110.Paragraph 8(1) (saving for certain provisions repealed by this Act...

        9. Eligibility for tax credits

          1. 111.In relation to a distribution paid before 1 July 2009...

        10. Recovery of overpaid tax credits etc

          1. 112.Section 1110(5) and (6) and section 1111(1) do not apply...

      24. Part 24 Corporation Tax Acts definitions etc

        1. 113.(1) Section 1139 has effect as if in subsection (4)(b)...

        2. 114.(1) In relation to shares and securities issued before 17...

        3. 115.If an order under paragraph 13(2) of Schedule 22 to...

    3. SCHEDULE 3

      Repeals and revocations

      1. Part 1 General

      2. Part 2 Repeals and revocations having effect for corporation tax purposes only

    4. SCHEDULE 4

      Index of defined expressions