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Corporation Tax Act 2010

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Changes over time for: Cross Heading: Marginal relief

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Changes to legislation:

Corporation Tax Act 2010, Cross Heading: Marginal relief is up to date with all changes known to be in force on or before 14 May 2025. There are changes that may be brought into force at a future date. Changes that have been made appear in the content and are referenced with annotations. Help about Changes to Legislation

[F1Marginal reliefU.K.

Textual Amendments

F1Pt. 8 Ch. 3A inserted (with effect in accordance with Sch. 1 para. 22 of the amending Act) by Finance Act 2014 (c. 26), Sch. 1 para. 5(3)

279BCompany with only ring fence profitsU.K.

(1)This section applies if—

(a)a company is UK resident in an accounting period,

[F2(ab)it is not a close investment-holding company in the period,]

(b)its augmented profits of the accounting period—

(i)exceed the lower limit, but

(ii)do not exceed the upper limit, and

(c)its augmented profits of that period consist exclusively of ring fence profits.

(2)The corporation tax charged on the company's taxable total profits of the accounting period is reduced by an amount equal to—

where—

R is the [F3ring fence marginal] relief fraction,

U is the upper limit,

A is the amount of the augmented profits, and

N is the amount of the taxable total profits.

(3)In this Chapter “the [F4ring fence marginal] relief fraction” means 11/400ths.

Textual Amendments

F2S. 279B(1)(ab) inserted (with effect in accordance with Sch. 1 para. 34 of the amending Act) by Finance Act 2021 (c. 26), Sch. 1 para. 6(a)

F3Words in s. 279B(2) substituted (with effect in accordance with Sch. 1 para. 34 of the amending Act) by Finance Act 2021 (c. 26), Sch. 1 para. 6(b)

F4Words in s. 279B(3) substituted (with effect in accordance with Sch. 1 para. 34 of the amending Act) by Finance Act 2021 (c. 26), Sch. 1 para. 6(c)

279CCompany with ring fence profits and other profitsU.K.

(1)This section applies if—

(a)a company is UK resident in an accounting period,

[F5(ab)it is not a close investment-holding company in the period,]

(b)its augmented profits of the accounting period—

(i)exceed the lower limit, but

(ii)do not exceed the upper limit, and

(c)its augmented profits of that period consist of both ring fence profits and other profits.

[F6(2)The corporation tax charged on the company's taxable total profits of the accounting period is reduced by the total of—

(a)the sum equal to the ring fence marginal relief fraction of the ring fence amount, and

(b)the sum equal to the standard marginal relief fraction of the remaining amount.]

Textual Amendments

F5S. 279C(1)(ab) inserted (with effect in accordance with Sch. 1 para. 34 of the amending Act) by Finance Act 2021 (c. 26), Sch. 1 para. 7(2)

F6S. 279C(2) substituted (with effect in accordance with Sch. 1 para. 34 of the amending Act) by Finance Act 2021 (c. 26), Sch. 1 para. 7(3)

279DThe ring fence amountU.K.

(1)In section 279C “the ring fence amount” means the amount given by the formula—

(2)In this section—

UR is the amount given by multiplying the upper limit by—

AR is the total amount of any ring fence profits that form part of the augmented profits of the accounting period,

NR is the total amount of any ring fence profits that form part of the taxable total profits of the accounting period, and

A is the amount of the augmented profits of the accounting period.

[F7279DAThe remaining amountU.K.

(1)In section 279C “the remaining amount” means the amount given by the formula—

(2)In this section—

  • UZ is the amount given by multiplying the upper limit by—

  • AZ is the total amount of any profits other than ring fence profits that form part of the augmented profits of the accounting period,

  • NZ is the total amount of any profits other than ring fence profits that form part of the taxable total profits of the accounting period, and

  • A is the amount of the augmented profits of the accounting period.]]

Textual Amendments

F7S. 279DA inserted (with effect in accordance with Sch. 1 para. 34 of the amending Act) by Finance Act 2021 (c. 26), Sch. 1 para. 8

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