Section 590 — Corporation Tax Act 2009: Disregard of subordinate or small value underlying subject matter

Disregard of subordinate or small value underlying subject matter 590 1 This section applies in relation to a relevant contract if its underlying subject matter consists only of—

a excluded property, and b other underlying subject matter which is—

i subordinate in relation to any of the excluded property, or ii of small value in comparison with the value of the underlying subject matter as a whole.

2 The underlying subject matter of the contract is treated for the purposes of this Part as if it consisted wholly of excluded property.

3 For the purposes of this section, whether part of the underlying subject matter of a relevant contract of a company is subordinate or of small value is to be determined by reference to the time when the company enters into or acquires the contract.

4 In this section “ excluded property ” has the same meaning as in section 589.