Corporation Tax Act 2009
Sections and provisions with full text and the judgments that cite each one.
Section 407 — Postponement until redemption of debits for connected companies' deeply discounted securities
Postponement until redemption of debits for connected companies' deeply discounted securities 407 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 408 — Companies connected for section 407
Companies connected for section 407 408 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 409 — Postponement until redemption of debits for close companies' deeply discounted securities
Postponement until redemption of debits for close companies' deeply discounted securities 409 1 This section applies for any accounting period (“ the relevant period ”) if— a a debtor relationship of…
Section 410 — Exceptions to section 409
Exceptions to section 409 410 1 Section 409 does not apply for any accounting period (“ the relevant period ”) if any of the following conditions are met— a the corresponding creditor relationship…
Section 411 — Interpretation of section 409
Interpretation of section 409 411 1 Section 472 (meaning of “control”) applies for the purposes of section 409 and this section. 2 A person who is a participator in a company which controls another…
Section 412 — Persons indirectly standing in the position of creditor
Persons indirectly standing in the position of creditor 412 1 For the purposes of sections 407(1)(b) and 409 a person is treated as standing in the position of a creditor if the person indirectly…
Section 413 — Issue of funding bonds
Issue of funding bonds 413 1 This section applies to the issue of funding bonds to a creditor in respect of a liability to pay interest on a debt incurred by a body corporate, a government, a public…
Section 414 — Redemption of funding bonds
Redemption of funding bonds 414 1 The redemption of funding bonds is not treated as the payment of interest on a debt for the purposes of the Corporation Tax Acts if their issue was treated as the…
Section 415 — Loan relationships with embedded derivatives
Loan relationships with embedded derivatives 415 1 This section applies if in accordance with generally accepted accounting practice a company treats the rights and liabilities under a loan…
Section 416 — Election for application of sections 415 and 585
Election for application of sections 415 and 585 416 1 This section applies if— a a company is subject to old UK GAAP for a period of account, b at the beginning of its first relevant period of…
Section 417 — Further provisions about elections under section 416
Further provisions about elections under section 416 417 1 An election under section 416 must be made not later than 90 days after the acquisition of the relevant assets or, if there is more than one…
Section 418 — Loan relationships involving connected debtor and creditor where debits exceed credits
Loan relationships involving connected debtor and creditor where debits exceed credits 418 1 This section applies if— a two connected companies are party to a loan relationship, one (“ the debtor ”)…
Section 418A — Cases involving host contract
Cases involving host contract 418A 1 This section applies where the debtor or the creditor, in accordance with generally accepted accounting practice, treats the rights and liabilities under the loan…
Section 419 — Section 418: supplementary
Section 418: supplementary 419 1 References in section 418 to a company being a party to a loan relationship as debtor or creditor include a company which indirectly stands in the position of a…
Section 420 — Assumptions where options etc apply
Assumptions where options etc apply 420 1 This section applies if— a the answer to any question specified in subsection (2)— i depends on the exercise of an option by a party to a loan relationship…
Section 420A — Amounts payable in respect of hybrid capital instruments
Amounts payable in respect of hybrid capital instruments 420A 1 This section applies if a loan relationship is a hybrid capital instrument for an accounting period of the debtor. 2 The Corporation…
Section 421 — Introduction to Chapter
Introduction to Chapter 421 1 This Chapter applies if— a condition A or B is met, and b each of the companies mentioned in subsection (3)(a) or (4)(a) makes a claim under this section, but see…
Section 422 — Transfer of loan relationship at notional carrying value
Transfer of loan relationship at notional carrying value 422 1 This section applies if in the course of the transfer of business the transferor transfers an asset or liability representing a loan…
Section 423 — Transferor using fair value accounting
Transferor using fair value accounting 423 1 This section applies instead of section 422 if, in a case where that section would otherwise apply, the transferor is regarded for the purposes of this…
Section 424 — Reorganisations involving loan relationships
Reorganisations involving loan relationships 424 1 This section applies if— a sections 127 to 130 of TCGA 1992 (reorganisations: equation of original shares and new holding)— i apply in relation to a…
Section 425 — Original holder using fair value accounting
Original holder using fair value accounting 425 1 This section applies instead of section 424 if, in a case where that section would otherwise apply, the original holder is regarded for the purposes…
Section 426 — Tax avoidance etc
Tax avoidance etc 426 1 This Chapter does not apply in relation to the transfer of business if— a the transfer of business is not effected for genuine commercial reasons, or b the transfer of…
Section 427 — Procedure on application for clearance
Procedure on application for clearance 427 1 This section applies in relation to an application under section 426(2). 2 The application must be in writing and must contain particulars of the…
Section 428 — Decision on application for clearance
Decision on application for clearance 428 1 The Commissioners for Her Majesty's Revenue and Customs must notify their decision on an application under section 426(2) to the applicant— a within 30…
Section 429 — Disapplication of Chapter where transparent entities involved
Disapplication of Chapter where transparent entities involved 429 1 This Chapter does not apply in relation to the transfer of business if the transferor is a transparent entity. 2 If any transferee…
Section 430 — Interpretation
Interpretation 430 1 In this Chapter “ company ” means any entity listed as a company in Part A of Annex I to the Mergers Directive. 2 For the purposes of this Chapter, a company is resident in a…
Section 431 — Introduction to Chapter
Introduction to Chapter 431 1 This Chapter applies if the following conditions are met— a conditions A to D, b in the case of a merger within subsection (3)(a), (b) or (c), condition E, and c in the…
Section 432 — Meaning of “the transferee” and “transferor”
Meaning of “the transferee” and “transferor” 432 1 In this Chapter, “ the transferee ” means— a in relation to a merger within section 431(3)(a), the SE, b in relation to a merger within section…
Section 433 — Transfer of loan relationship at notional carrying value
Transfer of loan relationship at notional carrying value 433 1 This section applies if in the course of the merger a transferor transfers an asset or liability representing a loan relationship to the…
Section 434 — Transferor using fair value accounting
Transferor using fair value accounting 434 1 This section applies instead of section 433 if, in a case where that section would otherwise apply, the transferor is regarded for the purposes of this…
Section 435 — Reorganisations involving loan relationships
Reorganisations involving loan relationships 435 1 This section applies if— a sections 127 to 130 of TCGA 1992 (reorganisations: equation of original shares and new holding)— i apply in relation to a…
Section 436 — Original holder using fair value accounting
Original holder using fair value accounting 436 1 This section applies instead of section 435 if, in a case where that section would otherwise apply, the original holder is regarded for the purposes…
Section 437 — Tax avoidance etc
Tax avoidance etc 437 1 This Chapter does not apply in relation to the merger if— a the merger is not effected for genuine commercial reasons, or b the merger forms part of a scheme or arrangements…
Section 438 — Disapplication of Chapter where transparent entities involved
Disapplication of Chapter where transparent entities involved 438 1 This section applies if one or more of the merging companies is a transparent entity. 2 If as a result of the merger the assets and…
Section 439 — Interpretation
Interpretation 439 1 In this Chapter— “ company ” means any entity listed as a company in Part A of Annex I to the Mergers Directive, and “ co-operative society ” means a society registered under the…
Section 440 — Overview of Chapter
Overview of Chapter 440 1 This Chapter contains rules connected with tax avoidance. 2 In particular— a for rules about unallowable purposes ..., see sections 441 and 442 , b for rules relating to…
Section 441 — Loan relationships for unallowable purposes
Loan relationships for unallowable purposes 441 1 This section applies if in any accounting period a loan relationship of a company has an unallowable purpose. 2 The company may not bring into…
Section 442 — Meaning of “unallowable purpose”
Meaning of “unallowable purpose” 442 1 For the purposes of section 441 a loan relationship of a company has an unallowable purpose in an accounting period if, at times during that period, the…
Section 443 — Restriction of relief for interest where tax relief schemes involved
Restriction of relief for interest where tax relief schemes involved 443 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 444 — Transactions not at arm's length: general
Transactions not at arm's length: general 444 1 If— a credits or debits in respect of a loan relationship of a company are to be brought into account for the purposes of this Part in respect of a…
Section 445 — Disapplication of section 444 where Part 4 of TIOPA 2010 applies
Disapplication of section 444 where Part 4 of TIOPA 2010 applies 445 1 Section 444 does not apply in relation to credits or debits of a company if— a as a result of Part 4 of TIOPA 2010 (transfer…
Section 446 — Bringing into account adjustments made under Part 4 of TIOPA 2010
Bringing into account adjustments made under Part 4 of TIOPA 2010 446 1 This section deals with the credits and debits which are to be brought into account for the purposes of this Part as a result…
Section 446A — Non-market loans
Non-market loans 446A 1 This section applies as respects any accounting period if— a a company has a debtor relationship in the period, b the amount recognised in the company's accounts in respect of…
Section 447 — Exchange gains and losses on debtor relationships: loans disregarded under Part 4 of TIOPA 2010
Exchange gains and losses on debtor relationships: loans disregarded under Part 4 of TIOPA 2010 447 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 448 — Exchange gains and losses on debtor relationships: equity notes where holder associated with issuer
Exchange gains and losses on debtor relationships: equity notes where holder associated with issuer 448 1 This section applies if— a a company has a debtor relationship in an accounting period, b an…
Section 449 — Exchange gains and losses on creditor relationships: no corresponding debtor relationship
Exchange gains and losses on creditor relationships: no corresponding debtor relationship 449 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 450 — Meaning of “corresponding debtor relationship”
Meaning of “corresponding debtor relationship” 450 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 451 — Exception to section 449 where loan exceeds arm's length amount
Exception to section 449 where loan exceeds arm's length amount 451 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 452 — Exchange gains and losses where loan not on arm's length terms
Exchange gains and losses where loan not on arm's length terms 452 1 This subsection applies if— a a company would be treated as having a debtor relationship, or would be treated as borrowing more…
Section 453 — Connected parties deriving benefit from creditor relationships
Connected parties deriving benefit from creditor relationships 453 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .