Corporation Tax Act 2009
Sections and provisions with full text and the judgments that cite each one.
Section 1 — Overview of Act
Overview of Act 1 1 Part 2 of this Act contains basic provisions about the charge to corporation tax including— a the imposition of the charge to corporation tax on the income and chargeable gains of…
Section A1 — Overview of the Corporation Tax Acts
Overview of the Corporation Tax Acts A1 1 The main Acts relating to corporation tax are— a this Act (which covers the ground described in section 1), b CTA 2010 (which covers the ground described in…
Section 2 — Charge to corporation tax
Charge to corporation tax 2 1 Corporation tax is charged on profits of companies for any financial year for which an Act so provides. 2 In this Part “ profits ” means income and chargeable gains,…
Section 3 — Exclusion of charge to income tax
Exclusion of charge to income tax 3 1 The provisions of the Income Tax Acts relating to the charge to income tax do not apply to income of a company if— a the company is UK resident, or b the company…
Section 4 — Exclusion of charge to capital gains tax
Exclusion of charge to capital gains tax 4 Capital gains tax is not charged on gains accruing to a company in respect of which the company is chargeable to corporation tax, or would be so chargeable…
Section 5 — Territorial scope of charge
Territorial scope of charge 5 1 A UK resident company is chargeable to corporation tax on income on all its profits wherever arising (but see Chapter 3A for an exemption from charge in respect of…
Section 5A — Arrangements for avoiding tax
Arrangements for avoiding tax 5A 1 Subsection (3) applies if a company has entered into an arrangement the main purpose or one of the main purposes of which is to obtain a relevant tax advantage for…
Section 5B — Trade of dealing in or developing UK land
Trade of dealing in or developing UK land 5B 1 A non-UK resident company's “trade of dealing in or developing UK land” consists of — a any activities falling within subsection (2) which it carries…
Section 6 — Profits accruing in fiduciary or representative capacity
Profits accruing in fiduciary or representative capacity 6 1 A company is not chargeable to corporation tax on profits which accrue to it in a fiduciary or representative capacity except as respects…
Section 7 — Profits accruing under trusts
Profits accruing under trusts 7 Profits that accrue for the benefit of a company under a trust are treated for the purposes of the charge to corporation tax under section 2(1) as accruing directly to…
Section 8 — How tax is charged and assessed
How tax is charged and assessed 8 1 Corporation tax for a financial year is charged on profits arising in the year. 2 Corporation tax is calculated and chargeable, and assessments to corporation tax…
Section 9 — Beginning of accounting period
Beginning of accounting period 9 1 An accounting period of a company begins— a when the company comes within the charge to corporation tax, or b immediately after the end of the previous accounting…
Section 10 — End of accounting period
End of accounting period 10 1 An accounting period of a company comes to an end on the first occurrence of any of the following— a the ending of 12 months from the beginning of the accounting period,…
Section 11 — Companies with more than one accounting date
Companies with more than one accounting date 11 1 This section applies if a company carrying on more than one trade— a does not have the same accounting date for each of the trades, and b does not…
Section 12 — Companies being wound up
Companies being wound up 12 1 This section applies if a company is being wound up. 2 An accounting period of the company ends immediately before the winding up starts. 3 An accounting period of the…
Section 13 — Overview of Chapter
Overview of Chapter 13 1 This Chapter contains rules for determining the residence of companies. 2 Section 14 gives the main rule for companies incorporated in the United Kingdom (including SEs and…
Section 14 — Companies incorporated in the United Kingdom
Companies incorporated in the United Kingdom 14 1 A company which is incorporated in the United Kingdom is UK resident for the purposes of the Corporation Tax Acts. 2 Accordingly, even if a different…
Section 15 — Continuation of residence established under common law
Continuation of residence established under common law 15 1 This section applies to a company which is neither— a incorporated in the United Kingdom, nor b resident in the United Kingdom by virtue of…
Section 16 — SEs which transfer registered office to the United Kingdom
SEs which transfer registered office to the United Kingdom 16 1 This section applies to an SE which transfers its registered office to the United Kingdom in accordance with Article 8 of Council…
Section 17 — SCEs which transfer registered office to the United Kingdom
SCEs which transfer registered office to the United Kingdom 17 1 This section applies to an SCE which transfers its registered office to the United Kingdom in accordance with Article 7 of Council…
Section 18 — Companies treated as non-UK resident under double taxation arrangements
Companies treated as non-UK resident under double taxation arrangements 18 1 This section applies to a company which is treated as— a resident in a territory outside the United Kingdom, and b non-UK…
Section 18A — Exemption for profits or losses of foreign permanent establishments
Exemption for profits or losses of foreign permanent establishments 18A 1 If a ... company makes an election under this section, exemption adjustments are to be made at the appropriate stages in…
Section 18CA — Income arising from immovable property
Income arising from immovable property 18CA The references in section 18A(6) to profits which would be taken to be attributable to the permanent establishment of a company in a territory include any…
Section 18HA — Modification of Chapter 3 of Part 9A of TIOPA 2010
Modification of Chapter 3 of Part 9A of TIOPA 2010 18HA Chapter 3 of Part 9A of TIOPA 2010 (the CFC charge gateway: determining which of Chapters 4 to 8 applies) applies for the purposes of section…
Section 18IA — The excluded territories exemption
The excluded territories exemption 18IA 1 Chapter 11 of Part 9A of TIOPA 2010 (controlled foreign companies: the excluded territories exemption) applies for the purposes of section 18G(1)(c) with the…
Section 18B — Chargeable gains etc
Chargeable gains etc 18B 1 The exemption adjustments required to be made by section 18A(1) include, in the case of any gains or losses on the disposal or realisation of assets which are relevant in…
Section 18CB — Profits and losses from investment business
Profits and losses from investment business 18CB 1 In determining any relevant profits amount or relevant losses amount under section 18A(6) or (7) in relation to a company, there are to be left out…
Section 18HB — Modification of Chapter 4 of Part 9A of TIOPA 2010
Modification of Chapter 4 of Part 9A of TIOPA 2010 18HB 1 Chapter 4 of Part 9A of TIOPA 2010 (the CFC charge gateway: profits attributable to UK activities) applies for the purposes of section 18H(2)…
Section 18IB — The low profits exemption
The low profits exemption 18IB Chapter 12 of Part 9A of TIOPA 2010 (controlled foreign companies: the low profits exemption) applies for the purposes of section 18G(1)(c) with the omission of section…
Section 18C — Capital allowances etc
Capital allowances etc 18C 1 Any allowance under Part 2 of CAA 2001 which, but for section 18A and for section 15(2A)(b) of CAA 2001, could be claimed under section 3(1) of that Act in respect of…
Section 18HC — Modification of Chapter 5 of Part 9A of TIOPA 2010
Modification of Chapter 5 of Part 9A of TIOPA 2010 18HC Chapter 5 of Part 9A of TIOPA 2010 (the CFC charge gateway: non-trading finance profits) applies for the purposes of section 18H(2) with the…
Section 18IC — The low profit margin exemption
The low profit margin exemption 18IC 1 Chapter 13 of Part 9A of TIOPA 2010 (controlled foreign companies: the low profit margin exemption) applies for the purposes of section 18G(1)(c) with the…
Section 18D — Payments subject to deduction
Payments subject to deduction 18D 1 In determining any relevant profits amount or relevant losses amount under section 18A(6) or (7) in relation to a company there are to be left out of account…
Section 18HD — Modification of Chapter 7 of Part 9A of TIOPA 2010
Modification of Chapter 7 of Part 9A of TIOPA 2010 18HD Chapter 7 of Part 9A of TIOPA 2010 (the CFC charge gateway: captive insurance business) applies for the purposes of section 18H(2) with the…
Section 18ID — The tax exemption
The tax exemption 18ID 1 Chapter 14 of Part 9A of TIOPA 2010 (controlled foreign companies: the tax exemption) applies for the purposes of section 18G(1)(c) with the following modifications. 2 At…
Section 18E — Employee share acquisitions
Employee share acquisitions 18E 1 Any relief which would be given under Chapter 2 or 3 of Part 12 is to be taken into account in determining any relevant profits amount or relevant losses amount in…
Section 18HE — Modification of Chapter 9 of Part 9A of TIOPA 2010
Modification of Chapter 9 of Part 9A of TIOPA 2010 18HE 1 Chapter 9 of Part 9A of TIOPA 2010 (exemptions for profits from qualifying loan relationships) applies for the purposes of section 18H(2)…
Section 18F — Effect of election
Effect of election 18F 1 An election made by a company under section 18A— a (subject to subsections (6) to (8) ) is irrevocable, and b applies to all accounting periods of the company beginning on or…
Section 18G — Anti-diversion rule
Anti-diversion rule 18G 1 This section applies for the purposes of this Chapter for any relevant accounting period (“period X”) of a company (“company X”) in relation to a territory outside the…
Section 18H — What are “diverted profits”?
What are “diverted profits”? 18H 1 In section 18G(1)(b) “ diverted profits ” means so much of company X's total profits of period X as pass through the diverted profits gateway. 2 To determine the…
Section 18I — Exemptions from anti-diversion rule
Exemptions from anti-diversion rule 18I 1 The exemptions referred to in section 18G(1)(c) are the exemptions set out in Chapters 11 to 14 of Part 9A of TIOPA 2010 (controlled foreign companies:…
Section 18J — Companies with total opening negative amount
Companies with total opening negative amount 18J 1 The following sections make provision about a company in relation to which an election under section 18A has effect if there is a total opening…
Section 18K — Total opening negative amount: “matching”
Total opening negative amount: “matching” 18K 1 At the end of each relevant accounting period of the company (starting with the first) the total opening negative amount is to be reduced (or further…
Section 18L — Streaming
Streaming 18L 1 If a streaming election has effect in relation to the company sections 18M and 18N apply (instead of section 18K). 2 For the purposes of this section “ streaming election ” means an…
Section 18M — Streamed opening negative amounts: “matching”
Streamed opening negative amounts: “matching” 18M 1 At the end of each relevant accounting period of the company (starting with the first) the streamed opening negative amount in relation to a…
Section 18N — Residual opening negative amount: “matching”
Residual opening negative amount: “matching” 18N 1 At the end of each relevant accounting period of the company (starting with the first) the residual opening negative amount is to be reduced (or…
Section 18O — Transfers of foreign permanent establishment business
Transfers of foreign permanent establishment business 18O 1 This section applies if— a business carried on by a company (“ the transferor ”) through a permanent establishment in a territory outside…
Section 18P — Exclusions
Exclusions 18P 1 If a company is a small company at any time during a relevant accounting period, there is for that relevant accounting period no relevant profits amount or relevant losses amount for…
Section 18Q — Insurance companies
Insurance companies 18Q 1 So much of the profits or losses of a company as consists of profits or losses arising from basic life assurance and general annuity business ... is not to be regarded as…
Section 18R — Meaning of “full treaty territory”
Meaning of “full treaty territory” 18R 1 For the purposes of this Chapter a territory is a “full treaty territory” if— a double taxation arrangements have been made in relation to the territory, and…