Corporation Tax Act 2009
Sections and provisions with full text and the judgments that cite each one.
Section 486 — Exclusion of exchange gains and losses in respect of tax debts etc
Exclusion of exchange gains and losses in respect of tax debts etc 486 1 No exchange gains or losses arise for the purposes of this Chapter if the money debt by reference to which the relevant…
Section 486A — Overview
Overview 486A 1 This Chapter provides for Part 5 to apply in relation to returns which are economically equivalent to interest (see section 486B). 2 For exclusions from this Chapter, see— a section…
Section 486B — Disguised interest to be regarded as profit from loan relationship
Disguised interest to be regarded as profit from loan relationship 486B 1 Where a company is party to an arrangement which produces for the company a return in relation to any amount which is…
Section 486C — Exclusion where return otherwise taxable
Exclusion where return otherwise taxable 486C 1 This Chapter does not apply to an arrangement which produces a return for a company if or to the extent that the return— a is charged to corporation…
Section 486D — Exclusion where arrangement has no tax avoidance purpose
Exclusion where arrangement has no tax avoidance purpose 486D 1 This Chapter does not apply in relation to a return produced by an arrangement to which a company is a party unless it is reasonable to…
Section 486E — Excluded shares
Excluded shares 486E 1 This Chapter does not apply in relation to an accounting period (“ the relevant accounting period ”) of a company (“the holding company”) for which an arrangement produces a…
Section 486F — Introduction to Chapter
Introduction to Chapter 486F 1 This Chapter provides for Part 5 to apply in relation to a company to which an income stream transfer is made (“ the transferee ”). 2 An “income stream transfer” is a…
Section 486G — Consideration to be treated as loan relationship
Consideration to be treated as loan relationship 486G 1 For the purposes of this Part— a the consideration for the transfer of the right to relevant receipts is to be treated as a money debt which is…
Section 487 — Overview of Chapter
Overview of Chapter 487 1 This Chapter provides for the Corporation Tax Acts to apply in some circumstances to holdings in open-ended investment companies, unit trust schemes and offshore funds as if…
Section 488 — Meaning of “open-ended investment company” etc
Meaning of “open-ended investment company” etc 488 1 Sections 613 and 615(3) of CTA 2010 (meaning of “open-ended investment company” and “company” and application to parts of umbrella companies)…
Section 489 — Meaning of “offshore fund” etc
Meaning of “offshore fund” etc 489 Sections 355 to 363 of TIOPA 2010 (meaning of “offshore fund” and application to parts of umbrella funds and classes of interests in offshore funds) apply for the…
Section 490 — Holdings in OEICs, unit trusts and offshore funds treated as creditor relationship rights
Holdings in OEICs, unit trusts and offshore funds treated as creditor relationship rights 490 1 This section applies if— a at any time in an accounting period of a company it holds— i any shares in…
Section 491 — Holding coming within section 490: opening valuations
Holding coming within section 490: opening valuations 491 1 This section applies if— a a relevant holding is held by a company both— i at the end of one accounting period (“ the first period ”), and…
Section 492 — Holding coming within section 490: calculation to undo avoidance
Holding coming within section 490: calculation to undo avoidance 492 1 Subsection (2) applies if— a section 490 applies for an accounting period of a company to a relevant holding held by the…
Section 493 — The qualifying investments test
The qualifying investments test 493 1 An open-ended investment company, a unit trust scheme or an offshore fund meets the qualifying investments test for the purposes of this Chapter if the market…
Section 494 — Meaning of “qualifying investments”
Meaning of “qualifying investments” 494 1 In section 493 “ qualifying investments ”, in relation to an open-ended investment company, a unit trust scheme or an offshore fund, means investments of the…
Section 495 — Qualifying holdings
Qualifying holdings 495 1 For the purposes of section 494(1)(d) a holding in an open-ended investment company, a unit trust scheme or an offshore fund is a qualifying holding at any time if— a at…
Section 496 — Meaning of “hedging relationship”
Meaning of “hedging relationship” 496 1 For the purposes of section 494, in relation to an open-ended investment company, a unit trust scheme or an offshore fund, there is a hedging relationship…
Section 497 — Power to change investments that are qualifying investments
Power to change investments that are qualifying investments 497 1 The Treasury may by order amend sections 493 to 496 so as to extend or restrict the descriptions of investments of an open-ended…
Section 498 — Building society dividends and interest
Building society dividends and interest 498 1 This section deals with how building society dividends and interest are dealt with for corporation tax purposes. 2 Liability to pay building society…
Section 499 — Registered society payments treated as interest under loan relationship
Registered society payments treated as interest under loan relationship 499 1 Any dividend, bonus or other sum payable to a shareholder in— a a registered society , or b a UK agricultural or fishing…
Section 500 — Exclusion of interest where failure to make return
Exclusion of interest where failure to make return 500 1 This section applies if for any accounting period a registered society is obliged to make a return under section 887(2) of ITA 2007. 2 If the…
Section 501 — Introduction to Chapter
Introduction to Chapter 501 1 This Chapter provides for alternative finance arrangements ... to be treated as loan relationships (see sections 509 and 510). 2 In this Part “ alternative finance…
Section 502 — Meaning of “financial institution”
Meaning of “financial institution” 502 1 In this Chapter “ financial institution ” means— a a bank, as defined by section 1120 of CTA 2010 , b a building society within the meaning of the Building…
Section 503 — Purchase and resale arrangements
Purchase and resale arrangements 503 1 This section applies to arrangements if— a they are entered into between two persons (“ the first purchaser ” and “ the second purchaser ”), and— i at least one…
Section 504 — Diminishing shared ownership arrangements : initial acquisition
Diminishing shared ownership arrangements : initial acquisition 504 1 This section applies to arrangements if under them— a a person (“ the financier ”) acquires a beneficial interest in an asset, aa…
Section 504A — Diminishing shared ownership arrangements: refinancing
Diminishing shared ownership arrangements: refinancing 504A 1 This section applies to arrangements if under them— a a person (“ the customer ”) has a beneficial interest in an asset, b the customer…
Section 505 — Deposit arrangements
Deposit arrangements 505 1 This section applies to arrangements if under them— a a person (“the depositor”) deposits money with a financial institution, b the money, together with money deposited…
Section 506 — Profit share agency arrangements
Profit share agency arrangements 506 1 This section applies to arrangements if under them— a a person (“the principal”) appoints an agent, ab one or both of the principal and agent is a financial…
Section 507 — Investment bond arrangements
Investment bond arrangements 507 1 This section applies to arrangements if— a they provide for one person (“the bond-holder”) to pay a sum of money (“the capital”) to another (“the bond-issuer”), b…
Section 508 — Provision not at arm's length: exclusion of arrangements from sections 503 to 507
Provision not at arm's length: exclusion of arrangements from sections 503 to 507 508 1 Arrangements to which this section applies are not— a purchase and resale arrangements, b diminishing shared…
Section 509 — Application of Part 5: general
Application of Part 5: general 509 1 Part 5 applies in relation to alternative finance arrangements to which a company (“A”) is a party as if the arrangements were a loan relationship to which A is a…
Section 510 — Application of Part 5 to particular alternative finance arrangements
Application of Part 5 to particular alternative finance arrangements 510 1 In the case of purchase and resale arrangements, Part 5 applies in relation to A as if— a the first purchase price were the…
Section 511 — Purchase and resale arrangements
Purchase and resale arrangements 511 1 In the case of purchase and resale arrangements, so much of the second purchase price as is specified under the following provisions of this section is…
Section 512 — Diminishing shared ownership arrangements
Diminishing shared ownership arrangements 512 1 In the case of diminishing shared ownership arrangements, payments by the customer under the arrangements are alternative finance return for the…
Section 513 — Other arrangements
Other arrangements 513 1 In the case of deposit arrangements, amounts paid or credited as mentioned in section 505(1)(c) by a financial institution under the arrangements (payments to depositor out…
Section 514 — Exclusion of alternative finance return from consideration for sale of assets
Exclusion of alternative finance return from consideration for sale of assets 514 1 If under purchase and resale arrangements an asset is sold by one party to the arrangements to the other party, the…
Section 515 — Diminishing shared ownership arrangements : further provision
Diminishing shared ownership arrangements : further provision 515 1 Diminishing shared ownership arrangements are not treated as a partnership for the purposes of the Corporation Tax Acts. 2 If,…
Section 515A — Diminishing shared ownership arrangements: further provision in respect of refinancing
Diminishing shared ownership arrangements: further provision in respect of refinancing 515A 1 This section applies in respect of diminishing shared ownership arrangements to which section 504A…
Section 516 — Treatment of principal under profit sharing agency arrangements
Treatment of principal under profit sharing agency arrangements 516 1 The principal under profit sharing agency arrangements is not treated for the purposes of the Corporation Tax Acts as entitled to…
Section 517 — Treatment of bond-holder under investment bond arrangements
Treatment of bond-holder under investment bond arrangements 517 1 This section applies for the purposes of the Corporation Tax Acts and irrespective of the position for other purposes. 2 The…
Section 518 — Investment bond arrangements: treatment as securities
Investment bond arrangements: treatment as securities 518 1 Investment bond arrangements are securities for the purposes of the Corporation Tax Acts. 2 For those purposes— a a reference in an…
Section 519 — Investment bond arrangements: other provisions
Investment bond arrangements: other provisions 519 1 A bond-issuer is not a securitisation company for the purposes of section 83 of FA 2005 (application of accounting standards to securitisation…
Section 520 — Provision not at arm's length: non-deductibility of relevant return
Provision not at arm's length: non-deductibility of relevant return 520 1 This section applies if arrangements to which section 508 (provision not at arm's length: exclusion of arrangements from…
Section 521 — Power to extend this Chapter to other arrangements
Power to extend this Chapter to other arrangements 521 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 521A — Introduction to Chapter
Introduction to Chapter 521A 1 This Chapter contains rules for Part 5 (and the other provisions of the Corporation Tax Acts) to apply in some cases as if at some times in the accounting period of a…
Section 521B — Application of Part 5 to certain shares as rights under creditor relationship
Application of Part 5 to certain shares as rights under creditor relationship 521B 1 This section applies in relation to the times in a company's accounting period when— a the company holds a share…
Section 521C — Shares accounted for as liabilities
Shares accounted for as liabilities 521C 1 This section applies to the share if— a the share would be accounted for by the issuing company as a liability in accordance with generally accepted…
Section 521D — Excepted shares
Excepted shares 521D 1 A share is an excepted share for the purposes of section 521C if it is— a a qualifying publicly-issued share (see subsection (2)), or b a share which mirrors a public issue…
Section 521E — Unallowable purpose
Unallowable purpose 521E 1 For the purposes of section 521C, the investing company holds the share for an unallowable purpose if the main purpose, or one of the main purposes for which the company…