Corporation Tax Act 2009
Sections and provisions with full text and the judgments that cite each one.
Section 656 — Introduction to section 658
Introduction to section 658 656 1 Section 658 (chargeable gain or allowable loss treated as accruing) applies to a derivative contract of a company for an accounting period if each of conditions A to…
Section 657 — Meaning of “exactly tracking contract” in section 656
Meaning of “exactly tracking contract” in section 656 657 1 This section applies for the purposes of section 656. 2 “ Exactly tracking contract ” means a contract where the amount which is to be paid…
Section 658 — Chargeable gain or allowable loss treated as accruing
Chargeable gain or allowable loss treated as accruing 658 1 Subsection (2) applies if— a the debtor relationship mentioned in section 656(2) comes to an end, and b an amount (“the discharge amount”)…
Section 659 — Meaning of “relevant credits” and “relevant debits”
Meaning of “relevant credits” and “relevant debits” 659 1 This section applies for the purposes of this Chapter. 2 In the case of a derivative contract which is not one to which section 650 (property…
Section 660 — Contract relating to holding in OEIC, unit trust or offshore fund
Contract relating to holding in OEIC, unit trust or offshore fund 660 1 This section applies if— a a company is a party to a relevant contract in two successive accounting periods, b section 587…
Section 661 — Contract which becomes derivative contract
Contract which becomes derivative contract 661 1 This section applies if— a a company is a party to a relevant contract which (not having been a derivative contract) becomes a derivative contract,…
Section 662 — Contracts ceasing to be derivative contracts
Contracts ceasing to be derivative contracts 662 1 This section applies if a company is a party to a relevant contract which ceases to be a derivative contract. 2 The company is treated for the…
Section 663 — Contracts to which section 641 applies
Contracts to which section 641 applies 663 1 This section applies in the case of a company if— a there are net section 641 losses for an accounting period (“the loss period”), b there are net section…
Section 664 — Meaning of certain expressions in section 663
Meaning of certain expressions in section 663 664 1 This section applies for the purposes of section 663. 2 If for an accounting period L exceeds G, there are net section 641 losses for the period of…
Section 665 — Introduction to section 666
Introduction to section 666 665 1 Section 666 (allowable loss treated as accruing) applies to a company for an accounting period if each of conditions A to F is met. 2 Condition A is that the company…
Section 666 — Allowable loss treated as accruing
Allowable loss treated as accruing 666 1 If A exceeds B, an allowable loss equal to the amount of the excess is treated as accruing to the company in the accounting period for the purposes of…
Section 667 — Shares acquired on exercise of non-embedded option
Shares acquired on exercise of non-embedded option 667 1 This section applies if— a a company is a party to a derivative contract in an accounting period, b the derivative contract is a plain vanilla…
Section 668 — Shares acquired on running of future to delivery
Shares acquired on running of future to delivery 668 1 This section applies if— a a company is a party to a derivative contract in an accounting period, b the derivative contract is a plain vanilla…
Section 669 — Meaning of G and L in sections 667 and 668
Meaning of G and L in sections 667 and 668 669 1 This section applies for the purposes of sections 667 and 668. 2 G is the sum of the credits brought into account under section 574 (non-trading…
Section 670 — Treatment of net gains and losses on exercise of option
Treatment of net gains and losses on exercise of option 670 1 This section applies if— a a derivative contract is one to which section 645 (creditor relationships: embedded derivatives which are…
Section 671 — Meaning of G, L and CV in section 670
Meaning of G, L and CV in section 670 671 1 This section applies for the purposes of section 670. 2 G is the sum of the amounts of any chargeable gains treated as accruing to the company under…
Section 672 — Treatment of net gains and losses on disposal of certain embedded derivatives
Treatment of net gains and losses on disposal of certain embedded derivatives 672 1 This section applies if— a a derivative contract is one to which section 648 (creditor relationships: embedded…
Section 673 — Meaning of G, L and CV in section 672
Meaning of G, L and CV in section 672 673 1 This section applies for the purposes of section 672. 2 G is the sum of the amounts of any chargeable gains treated as accruing to the company under…
Section 674 — Introduction to Chapter
Introduction to Chapter 674 1 This Chapter applies if— a condition A or B is met, and b each of the companies mentioned in subsection (2)(a) or (3)(a) makes a claim under this section, but see…
Section 675 — Transfer of derivative contract at notional carrying value
Transfer of derivative contract at notional carrying value 675 1 This section applies if in the course of the transfer of business the transferor transfers the rights and liabilities under a…
Section 676 — Transferor using fair value accounting
Transferor using fair value accounting 676 1 This section applies instead of section 675 if, in a case where that section would otherwise apply, the transferor uses fair value accounting as respects…
Section 677 — Tax avoidance etc
Tax avoidance etc 677 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 678 — Procedure on application for clearance
Procedure on application for clearance 678 1 This section applies in relation to an application under section 677(2). 2 The application must be in writing and must contain particulars of the…
Section 679 — Decision on application for clearance
Decision on application for clearance 679 1 The Commissioners for Her Majesty's Revenue and Customs must notify their decision on an application under section 677(2) to the applicant— a within 30…
Section 680 — Disapplication of Chapter where transparent entities involved
Disapplication of Chapter where transparent entities involved 680 1 This Chapter does not apply in relation to the transfer of business if the transferor is a transparent entity. 2 In this section “…
Section 681 — Interpretation
Interpretation 681 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 682 — Introduction to Chapter
Introduction to Chapter 682 1 This Chapter applies if the following conditions are met— a conditions A to D, b in the case of a merger within subsection (2)(a), (b) or (c), condition E, and c in the…
Section 683 — Meaning of “the transferee” and “transferor”
Meaning of “the transferee” and “transferor” 683 1 In this Chapter, “ the transferee ” means— a in relation to a merger within section 682(2)(a), the SE, b in relation to a merger within section…
Section 684 — Transfer of derivative contract at notional carrying value
Transfer of derivative contract at notional carrying value 684 1 This section applies if in the course of the merger a transferor transfers the rights and liabilities under a derivative contract to…
Section 685 — Transferor using fair value accounting
Transferor using fair value accounting 685 1 This section applies instead of section 684 if, in a case where that section would otherwise apply, the transferor uses fair value accounting as respects…
Section 686 — Tax avoidance etc
Tax avoidance etc 686 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 687 — Disapplication of Chapter where transparent entities involved
Disapplication of Chapter where transparent entities involved 687 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 688 — Interpretation
Interpretation 688 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 689 — Overview of Chapter
Overview of Chapter 689 1 This Chapter contains rules connected with tax avoidance. 2 In particular— a for rules about unallowable purposes, see sections 690 to 692, b for rules relating to credits…
Section 690 — Derivative contracts for unallowable purposes
Derivative contracts for unallowable purposes 690 1 This section applies if in any accounting period a derivative contract of a company has an unallowable purpose. 2 The company may not bring into…
Section 691 — Meaning of “unallowable purpose”
Meaning of “unallowable purpose” 691 1 For the purposes of sections 690 and 692, a derivative contract of a company has an unallowable purpose in an accounting period if the purposes for which, at…
Section 692 — Allowance of accumulated net losses
Allowance of accumulated net losses 692 1 This section applies if— a in any accounting period a derivative contract of a company has an unallowable purpose, and b there is a net loss in respect of…
Section 693 — Bringing into account adjustments under Part 4 of TIOPA 2010
Bringing into account adjustments under Part 4 of TIOPA 2010 693 1 This section deals with the credits and debits which are to be brought into account in accordance with this Part as a result of Part…
Section 694 — Exchange gains and losses
Exchange gains and losses 694 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 695 — Transfers of value to connected companies
Transfers of value to connected companies 695 1 This section applies if— a a company (“A”) paid an amount (“amount X”) to a company (“B”) for the grant of an option, b there is a failure to exercise…
Section 695A — Disguised distribution arrangements involving derivative contracts
Disguised distribution arrangements involving derivative contracts 695A 1 This section applies if— a a company (“A”) is a party to arrangements involving one or more derivative contracts (each of…
Section 696 — Derivative contracts with non-UK residents
Derivative contracts with non-UK residents 696 1 This section applies in relation to a company (“A”) if, as a result of any transaction— a A becomes a party to a derivative contract to which a non-UK…
Section 697 — Exceptions to section 696
Exceptions to section 696 697 1 Section 696 does not apply if A— a is a bank, building society, financial trader , recognised clearing house, recognised CSD ... or third country central counterparty…
Section 698 — Disposals for consideration not fully recognised by accounting practice
Disposals for consideration not fully recognised by accounting practice 698 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 698A — Debits arising from derecognition of derivative contracts
Debits arising from derecognition of derivative contracts 698A 1 This section applies where— a a company is at any time a party to tax avoidance arrangements, b as a result of those arrangements, a…
Section 698B — Counteracting effect of avoidance arrangements
Counteracting effect of avoidance arrangements 698B 1 Any derivative-related tax advantages that would (in the absence of this section) arise from relevant avoidance arrangements are to be…
Section 698C — Interpretation of section 698B
Interpretation of section 698B 698C 1 This section applies for the interpretation of section 698B (and this section). 2 “Arrangements” include any agreement, understanding, scheme, transaction or…
Section 698D — Examples of results that may indicate exclusion not applicable
Examples of results that may indicate exclusion not applicable 698D 1 Each of the following is an example of something which might indicate that arrangements whose main purpose, or one of whose main…
Section 699 — Priority of this Part for corporation tax purposes
Priority of this Part for corporation tax purposes 699 1 The amounts which are brought into account in accordance with this Part in respect of any matter are the only amounts which may be brought…
Section 700 — Relationship of this Part to Part 5: loan relationships
Relationship of this Part to Part 5: loan relationships 700 1 This section applies if— a a company is a party to a loan relationship because of a derivative contract, and b in accordance with this…