Section 279G — Finance Act 2014: “Augmented profits”

“Augmented profits” 279G 1 For the purposes of this Chapter a company's augmented profits of an accounting period are—

a the company's adjusted taxable total profits of that period, plus b any franked investment income received by the company that is not excluded by subsection (3).

2 A company's “adjusted taxable total profits” of a period are what would have been the company's taxable total profits of the period in the absence of sections 1(2A), 2B and 8(4A) of TCGA 1992 and section 2(2A) of CTA 2009 (certain gains on relevant high value disposals by companies etc chargeable to capital gains tax not corporation tax).

3 This subsection excludes any franked investment income which the company (“the receiving company”) receives from a company which is—

a a 51% subsidiary of—

i the receiving company, or ii a company of which the receiving company is a 51% subsidiary, or b a trading company or relevant holding company that is a quasi-subsidiary of the receiving company.

4 For the purposes of subsection (3)(b) a company is a quasi-subsidiary of the receiving company if—

a it is owned by a consortium of which the receiving company is a member, b it is not a 75% subsidiary of any company, and c no arrangements of any kind (whether in writing or not) exist by virtue of which it could become a 75% subsidiary of any company.