Corporation Tax Act 2009
Sections and provisions with full text and the judgments that cite each one.
Section 844 — Overview of Chapter
Overview of Chapter 844 1 This Chapter sets out special rules relating to transactions between related parties. 2 Sections 845 to 849A are about the rule that transfers between a company and a…
Section 845 — Transfer between company and related party treated as at market value
Transfer between company and related party treated as at market value 845 1 The basic rule is that a transfer of an intangible asset— a from a company to a related party, or b to a company from a…
Section 846 — Transfers where provision subject to transfer pricing but section 147(3) or (5) does not apply
Transfers where provision subject to transfer pricing but section 147(3) or (5) does not apply 846 1 This section applies to a person who is a company or related party to whom, or from whom, a…
Section 847 — Transfers involving other taxes
Transfers involving other taxes 847 1 This section applies if— a in a case where section 845(1) applies and the asset is transferred from the company to a related party, the transfer is at less than…
Section 848 — Tax-neutral transfers
Tax-neutral transfers 848 1 Section 845 does not apply if the transfer is tax-neutral for the purposes of this Part as a result of any provision in this Part. 2 For such provisions, see, in…
Section 848A — Assets held for purposes of exempt foreign permanent establishments
Assets held for purposes of exempt foreign permanent establishments 848A 1 This section applies if— a subsection (1) of section 775 (transfers within a group) would apply in relation to the transfer…
Section 849 — Transfers involving gifts of business assets
Transfers involving gifts of business assets 849 1 This section applies if— a the asset is transferred to the company mentioned in section 845(1), and b on a claim for relief under section 165 of…
Section 849A — Disincorporation relief: transfer values for post-FA 2002 goodwill
Disincorporation relief: transfer values for post-FA 2002 goodwill 849A 1 This section applies where— a a company transfers its business to some or all of the shareholders of the company, and b a…
Section 849AB — Grant of licence or other right treated as at market value
Grant of licence or other right treated as at market value 849AB 1 This section applies if— a a company which holds an intangible asset grants a licence or other right in respect of the asset to a…
Section 849B — Circumstances in which restrictions on debits in respect of goodwill etc apply
Circumstances in which restrictions on debits in respect of goodwill etc apply 849B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 849AC — Grants not at arm's length
Grants not at arm's length 849AC . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 849C — Restrictions in a case within section 849B(4) or (5)
Restrictions in a case within section 849B(4) or (5) 849C . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 849AD — Grants involving other taxes
Grants involving other taxes 849AD 1 This section applies if— a in a case where section 849AB applies and the licence or other right is granted by the company to a related party, the grant is at less…
Section 849D — Restrictions in a case within section 849B(6)
Restrictions in a case within section 849B(6) 849D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 850 — Part realisation involving related party acquisition: exclusion of roll-over relief
Part realisation involving related party acquisition: exclusion of roll-over relief 850 1 Chapter 7 (roll-over relief in case of realisation and reinvestment) does not apply in relation to the part…
Section 850A — Profit-making period in which some partners have losses
Profit-making period in which some partners have losses 850A 1 For any period of account, if— a the calculation under section 849 in relation to a partner (“A”) produces a profit, and b A's share…
Section 850B — Loss-making period in which some partners have profits
Loss-making period in which some partners have profits 850B 1 For any period of account, if— a the calculation under section 849 in relation to a partner (“A”) produces a loss, and b A's share…
Section 851 — Delayed payment of royalty by company to related party
Delayed payment of royalty by company to related party 851 1 This section applies if— a a royalty is payable by a company to or for the benefit of a related party, b the royalty is not paid in full…
Section 852 — Treatment of grants and other contributions to expenditure
Treatment of grants and other contributions to expenditure 852 1 This section applies if a grant or other payment is intended by the payer to meet, directly or indirectly, expenditure of a company on…
Section 853 — Grants to be left out of account for tax purposes
Grants to be left out of account for tax purposes 853 1 This section applies to the following grants (“exempt grants”)— a grants under Part 2 of the Industrial Development Act 1982 (c. 52) (regional…
Section 854 — Finance leasing etc
Finance leasing etc 854 1 The Treasury may make provision by regulations as to the application of this Part in relation to a company that is the finance lessor of an intangible asset that is the…
Section 855 — Further provision about regulations under section 854
Further provision about regulations under section 854 855 1 Regulations under section 854 may provide that this Part applies as if the asset were an intangible fixed asset of the finance lessor and…
Section 856 — Assets acquired or realised together
Assets acquired or realised together 856 1 Any reference in this Part to the acquisition or realisation of an asset includes a reference to the acquisition or realisation of that asset together with…
Section 857 — Deemed market value or arm’s length acquisition: adjustment where nil or negligible accounting value
Deemed market value or arm’s length acquisition: adjustment where nil or negligible accounting value 857 1 This section applies if— a a company is treated for the purposes of this Part as acquiring…
Section 858 — Fungible assets
Fungible assets 858 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 859 — Asset ceasing to be chargeable intangible asset: deemed realisation at market value
Asset ceasing to be chargeable intangible asset: deemed realisation at market value 859 1 If an asset ceases to be a chargeable intangible asset in relation to a company in any of the circumstances…
Section 860 — Asset ceasing to be chargeable intangible asset: postponement of gain
Asset ceasing to be chargeable intangible asset: postponement of gain 860 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 861 — Treatment of postponed gain on subsequent realisation
Treatment of postponed gain on subsequent realisation 861 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 862 — Treatment of postponed gain in other cases
Treatment of postponed gain in other cases 862 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 863 — Asset becoming chargeable intangible asset
Asset becoming chargeable intangible asset 863 1 This section applies if an asset becomes a chargeable intangible asset in relation to a company— a on the company becoming UK resident, b in the case…
Section 863A — Asset becoming chargeable intangible asset: EU exit charge
Asset becoming chargeable intangible asset: EU exit charge 863A 1 This section applies if— a an asset becomes a chargeable intangible asset in relation to a company by reason of an event specified in…
Section 864 — Tax avoidance arrangements to be ignored
Tax avoidance arrangements to be ignored 864 1 In determining whether a credit or a debit is to be brought into account under this Part and, if so, its amount, any tax avoidance arrangements are…
Section 865 — Debits for expenditure not generally deductible for tax purposes
Debits for expenditure not generally deductible for tax purposes 865 1 No debit may be brought into account for tax purposes under this Part in respect of expenditure that is not generally deductible…
Section 866 — Delayed payment of employees' remuneration
Delayed payment of employees' remuneration 866 1 This subsection applies if— a a debit in respect of employees' remuneration is recognised by a company for accounting purposes, and b apart from this…
Section 867 — Provisions supplementing section 866
Provisions supplementing section 866 867 1 For the purposes of section 866 a debit in respect of employees' remuneration recognised for accounting purposes includes an amount reserved in the accounts…
Section 868 — Delayed payment of pension contributions
Delayed payment of pension contributions 868 1 This section applies if— a a debit in respect of pension contributions is recognised by a company for accounting purposes, and b the contributions are…
Section 869 — Bad debts etc
Bad debts etc 869 1 No debit may be brought into account for the purposes of this Part in respect of a debt owed to the company, except— a by way of impairment loss, or b so far as the debt is…
Section 870 — Assumptions for calculating chargeable profits
Assumptions for calculating chargeable profits 870 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 870A — Claims for relief made under sections 152 and 153 of TCGA 1992
Claims for relief made under sections 152 and 153 of TCGA 1992 870A 1 Subsection (2) applies where— a a company has made a claim for relief under section 152 or 153 of TCGA 1992 (roll-over relief)…
Section 871 — Introduction to Chapter
Introduction to Chapter 871 1 This Chapter applies if— a there is a change of accounting policy in drawing up a company's accounts from one period of account to the next, and b the approach in each…
Section 872 — Adjustments in respect of change
Adjustments in respect of change 872 1 This section and section 873 apply if— a as a result of the change of accounting policy there is a difference (“the accounting difference”) between— i the…
Section 873 — Effect of application of section 872 in later period and subsequently
Effect of application of section 872 in later period and subsequently 873 1 A credit or debit that is required to be brought into account under section 872 is treated as arising at the beginning of…
Section 874 — Original asset not subject to fixed-rate writing down
Original asset not subject to fixed-rate writing down 874 1 This section and section 875 apply if— a the change of accounting policy results in an intangible fixed asset of the company that was…
Section 875 — Effect of application of section 874 in later period and subsequently
Effect of application of section 874 in later period and subsequently 875 1 A credit or debit that is required to be brought into account under section 874 is treated as arising at the beginning of…
Section 876 — Original asset subject to fixed-rate writing down
Original asset subject to fixed-rate writing down 876 1 This section applies if— a the change of accounting policy results in an intangible fixed asset of the company that was treated as one asset…
Section 877 — Election for fixed-rate writing down in relation to resulting asset
Election for fixed-rate writing down in relation to resulting asset 877 1 This section applies if— a the change of accounting policy results in an intangible fixed asset of the company that was…
Section 878 — Exclusion of credits or debits brought into account under other provisions
Exclusion of credits or debits brought into account under other provisions 878 1 A credit or debit is not required to be brought into account under this Chapter so far as a credit or debit…
Section 879 — Subsequent events affecting asset subject to adjustment under this Chapter
Subsequent events affecting asset subject to adjustment under this Chapter 879 1 On a further change of accounting policy affecting an intangible fixed asset in relation to which this Chapter has…
Section 879A — Introduction
Introduction 879A 1 This Chapter contains special rules about the debits to be brought into account by a company for tax purposes in respect of relevant assets. 2 In this Chapter “ relevant asset ”…
Section 879B — Requirement to write down at a fixed rate
Requirement to write down at a fixed rate 879B 1 This section applies if a company acquires or creates a relevant asset on or after 1 April 2019. 2 The company is to be treated as having made an…