Section 1219 — Corporation Tax Act 2009: Expenses of management of a company's investment business

Expenses of management of a company's investment business 1219 1 In calculating the corporation tax to which a company with investment business is liable for an accounting period, expenses of management of the company's investment business which are referable to that period are allowed as a deduction from the company's total profits. 1A A deduction under subsection (1) is to be made before any other deduction at Step 2 in section 4(2) of CTA 2010 (deductions from total profits).

2 For the purposes of this section expenses of management are expenses of management of a company's investment business so far as—

a they are in respect of so much of the company's investment business as consists of making investments, and b the investments concerned are not held for an unallowable purpose during the accounting period to which the expenses are referable.

3 But—

a no deduction is allowed under this section for expenses of a capital nature, and b no deduction is allowed under this section for expenses so far as they are otherwise deductible from total profits, or in calculating any component of total profits. There is an exception to paragraph (a) in section 1221(1).

4 Any apportionment needed for the purposes of subsection (2) must be made on a just and reasonable basis.

5 The amount deductible under subsection (1) may be reduced under section 1222.