Corporation Tax Act 2009
Sections and provisions with full text and the judgments that cite each one.
Section 328B — Meaning of “relevant exchange gain” and “relevant exchange loss”
Meaning of “relevant exchange gain” and “relevant exchange loss” 328B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 328C — Meaning of “test day”
Meaning of “test day” 328C . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 328D — Counterfactual currency movement assumptions
Counterfactual currency movement assumptions 328D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 328E — Counterfactual currency movement assumptions: treatment of options
Counterfactual currency movement assumptions: treatment of options 328E . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 328F — Meaning of “option”
Meaning of “option” 328F . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 328G — Meaning of “relevant contingent contract” and “operative condition”
Meaning of “relevant contingent contract” and “operative condition” 328G . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 328H — Other interpretative provisions
Other interpretative provisions 328H . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 329 — Pre-loan relationship and abortive expenses
Pre-loan relationship and abortive expenses 329 1 This section applies if— a a company may enter into a loan relationship or related transaction but has not yet done so, b it incurs any expenses for…
Section 330 — Debits in respect of pre-trading expenditure
Debits in respect of pre-trading expenditure 330 1 This section applies if— a a non-trading debit is given for an accounting period of a company for the purposes of this Part, and b within the period…
Section 330A — Company is not, or has ceased to be, party to loan relationship
Company is not, or has ceased to be, party to loan relationship 330A 1 This section applies if— a amounts in respect of a qualifying relationship are recognised in a company's accounts for an…
Section 330ZA — Debits referable to times before UK property business etc carried on
Debits referable to times before UK property business etc carried on 330ZA 1 This section applies if— a a non-UK resident company has debits in respect of a loan relationship to which it is a party…
Section 330B — Exclusion of debit where relief allowed to another
Exclusion of debit where relief allowed to another 330B A company is not to bring into account as a debit for the purposes of this Part as a result of section 330A an amount which— a is brought into…
Section 330C — Avoidance of double charge
Avoidance of double charge 330C 1 This section applies if at any time a company (“ the relevant company ”) is required by section 330A to bring into account as a credit for the purposes of this Part…
Section 331 — Company ceasing to be party to loan relationship
Company ceasing to be party to loan relationship 331 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 332 — Repo, stock lending and other transactions
Repo, stock lending and other transactions 332 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 333 — Company ceasing to be UK resident
Company ceasing to be UK resident 333 1 If a company ceases to be UK resident, this Part applies as if— a immediately before so ceasing the company had assigned the assets and liabilities which…
Section 334 — Non-UK resident company ceasing to hold loan relationship for section 333(2) purposes
Non-UK resident company ceasing to hold loan relationship for section 333(2) purposes 334 1 This section applies if an asset or liability representing a loan relationship of a company which is not UK…
Section 335 — Introduction to Chapter
Introduction to Chapter 335 1 This Chapter applies in the cases mentioned in— a section 336 (transfers of loans on group transactions), b section 337 (transfers of loans on insurance business…
Section 336 — Transfers of loans on group transactions
Transfers of loans on group transactions 336 1 The case referred to in section 335(1)(a) is where— a there is a transaction within subsection (2) or a series of transactions within subsection (3),…
Section 337 — Transfers of loans on insurance business transfers
Transfers of loans on insurance business transfers 337 1 The case referred to in section 335(1)(b) is where— a a transfer between two companies occurs to which this section applies, and b as a result…
Section 338 — Meaning of company replacing another as party to loan relationship
Meaning of company replacing another as party to loan relationship 338 1 References in this Chapter to one company (“A”) replacing another company (“B”) as a party to a loan relationship include…
Section 339 — Issues of new securities on certain cross-border reorganisations
Issues of new securities on certain cross-border reorganisations 339 1 The case referred to in section 335(1)(c) is where each of conditions A to D is met. 2 Condition A is that sections 127 to 130…
Section 340 — Group transfers and transfers of insurance business: transfer at notional carrying value
Group transfers and transfers of insurance business: transfer at notional carrying value 340 1 This section applies in the cases mentioned in— a section 336 (transfers of loans on group…
Section 341 — Transferor using fair value accounting
Transferor using fair value accounting 341 1 This section applies instead of section 340 if, in a case where that section would otherwise apply, the transferor is regarded for the purposes of this…
Section 342 — Issues of new securities on reorganisations: disposal at notional carrying value
Issues of new securities on reorganisations: disposal at notional carrying value 342 1 This section applies in the case mentioned in section 339. 2 For the purposes of this Part such debits and…
Section 343 — Receiving company using fair value accounting
Receiving company using fair value accounting 343 1 This section applies instead of section 342 if, in a case where that section would otherwise apply, the receiving company is regarded for the…
Section 344 — Introduction
Introduction 344 1 Sections 345 and 346 apply if— a this Chapter applies in the case mentioned in section 336 (transfers of loans on group transactions), b section 341 (transferor using fair value…
Section 345 — Transferee leaving group otherwise than because of exempt distribution
Transferee leaving group otherwise than because of exempt distribution 345 1 This section applies if— a the transferee ceases to be a member of the relevant group, and b it does not so cease just…
Section 346 — Transferee leaving group because of exempt distribution
Transferee leaving group because of exempt distribution 346 1 This section applies if— a the transferee ceases to be a member of the relevant group just because of a distribution which is exempt as a…
Section 347 — Disapplication of Chapter where transferor party to avoidance
Disapplication of Chapter where transferor party to avoidance 347 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 348 — Introduction: meaning of “connected companies relationship”
Introduction: meaning of “connected companies relationship” 348 1 This Chapter contains some general rules relating to connected companies relationships. 2 For the purposes of this Part a debtor…
Section 349 — Application of amortised cost basis to connected companies relationships
Application of amortised cost basis to connected companies relationships 349 1 This section applies if a loan relationship is a connected companies relationship for an accounting period. 2 The…
Section 350 — Companies beginning to be connected
Companies beginning to be connected 350 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 351 — Companies ceasing to be connected
Companies ceasing to be connected 351 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 352 — Disregard of related transactions
Disregard of related transactions 352 1 This section applies in an accounting period if— a section 349 applies in respect of a creditor relationship of a company for the period, and b a related…
Section 352A — Exclusion of credits on reversal of disregarded loss
Exclusion of credits on reversal of disregarded loss 352A 1 If as a result of section 352 the debits brought into account by a company in respect of a loan relationship are reduced, no credit is to…
Section 352B — Eliminating tax mismatch for loan relationships with qualifying link
Eliminating tax mismatch for loan relationships with qualifying link 352B 1 This section applies if— a section 349 applies in respect of a loan relationship of a company for an accounting period…
Section 353 — Introduction to Chapter
Introduction to Chapter 353 1 This Chapter contains rules about impairment losses and releases of debts in the case of companies connected with other companies. 2 In particular, see— a sections 354…
Section 354 — Exclusion of debits for impaired or released connected companies debts
Exclusion of debits for impaired or released connected companies debts 354 1 The general rule is that no impairment loss or release debit in respect of a company's creditor relationship is to be…
Section 355 — Cessation of connection
Cessation of connection 355 1 This section applies if, in the case of a creditor relationship of a company— a an impairment loss or release debit is excluded by section 354 from being brought into…
Section 356 — Exception to section 354: swapping debt for equity
Exception to section 354: swapping debt for equity 356 1 An impairment loss or release debit in relation to a liability to pay any amount to a company (“the creditor company”) under its creditor…
Section 357 — Exception to section 354: insolvent creditors
Exception to section 354: insolvent creditors 357 1 An impairment loss or release debit is not prevented from being brought into account by section 354 in relation to an amount accruing to a company…
Section 358 — Exclusion of credits on release of connected companies debts: general
Exclusion of credits on release of connected companies debts: general 358 1 This section applies if— a a liability to pay an amount under a debtor relationship of a company (“D”) is released, and b…
Section 359 — Exclusion of credits on release of connected companies debts during creditor's insolvency
Exclusion of credits on release of connected companies debts during creditor's insolvency 359 1 This section applies if— a a liability to pay an amount under a company's debtor relationship is…
Section 360 — Exclusion of credits on reversal of impairments of connected companies debts
Exclusion of credits on reversal of impairments of connected companies debts 360 1 If an impairment loss is prevented from being brought into account by section 354, no credit in respect of any…
Section 361 — Acquisition of creditor rights by connected company at undervalue
Acquisition of creditor rights by connected company at undervalue 361 1 This section applies if— a a company (“D”) is a party to a loan relationship as debtor, b another company (“C”) becomes a party…
Section 361A — The corporate rescue exception
The corporate rescue exception 361A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 361B — The debt-for-debt exception
The debt-for-debt exception 361B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 361C — The equity-for-debt exception
The equity-for-debt exception 361C 1 For the purposes of section 361 the “equity-for-debt exception” applies if the following two conditions are met. 2 The first condition is that the acquisition is…
Section 361D — Corporate rescue: debt released shortly after acquisition
Corporate rescue: debt released shortly after acquisition 361D 1 This section applies if— a the case is one in which section 361 would otherwise apply, b within 60 days after C becomes a party to the…