Corporation Tax Act 2010
Sections and provisions with full text and the judgments that cite each one.
Section 357WH — Allocation of Northern Ireland profits etc of firm to company
Allocation of Northern Ireland profits etc of firm to company 357WH 1 This section applies where the profits or losses of a firm's trade that are determined under section 1259(3) or (4) of CTA 2009…
Section 357XH — Power to amend definition of “excluded trade” or “excluded activity”
Power to amend definition of “excluded trade” or “excluded activity” 357XH 1 The Treasury may by regulations amend this Chapter so as to alter the meaning of “excluded trade” or “ excluded activity ”…
Section 357YH — Countering effect of avoidance arrangements
Countering effect of avoidance arrangements 357YH 1 Any ... tax advantages that would (in the absence of this section) arise from relevant avoidance arrangements are to be counteracted by the making…
Section 357BI — Excluded debits
Excluded debits 357BI For the purposes of this Part “ excluded debits ” means— a the amount of any debits which are treated as expenses of a trade by virtue of— i section 297 of CTA 2009 (debits in…
Section 357CI — Routine return figure
Routine return figure 357CI 1 To determine the routine return figure in relation to a trade of a company for an accounting period— Step 1 Take the aggregate of any routine deductions made by the…
Section 357I — The Northern Ireland rate
The Northern Ireland rate 357I 1 The Northern Ireland rate for a financial year is— a if a resolution of the Northern Ireland Assembly— i sets a rate under section 357IA for the year, and ii is…
Section 357JI — Transfers of trade without a change of ownership
Transfers of trade without a change of ownership 357JI 1 This section applies where— a Chapter 1 of Part 22 (transfers of trade without a change of ownership) applies to the transfer of a trade, and…
Section 357LI — Lloyd's agents
Lloyd's agents 357LI 1 This section applies if a transaction is carried out on behalf of a company in the course of the company's trade by a person in Northern Ireland acting as a members' agent or…
Section 357NI — Interest or other financing costs and receipts
Interest or other financing costs and receipts 357NI 1 No deduction is allowed in calculating the profits attributable to the company's NI RE for payments of interest or other financing costs by the…
Section 357OI — Goodwill
Goodwill 357OI For the purposes of section 357OH(1) (pre-commencement asset), goodwill is treated as created— a before the commencement day in a case in which the business in question was carried on…
Section 357UI — Provisional entitlement to relief
Provisional entitlement to relief 357UI Section 1217N(3) of CTA 2009 (provisional entitlement to relief: definition of “the relieving provisions”) has effect as if the reference to section 1217H of…
Section 357XI — Power to make provision about meaning of “back-office activities”
Power to make provision about meaning of “back-office activities” 357XI 1 The Treasury may by regulations make provision about the meaning of “ back-office activities ” for the purposes of this Part.…
Section 357YI — Interpretation of section 357YH
Interpretation of section 357YH 357YI 1 This section applies for the interpretation of section 357YH (and this section). 2 “Arrangements” include any agreement, understanding, scheme, transaction or…
Section 357BJ — Routine return figure
Routine return figure 357BJ 1 This section applies for the purpose of calculating the routine return figure for a relevant IP income sub-stream established at Step 2 in section 357BF(2) in…
Section 357CJ — Routine deductions
Routine deductions 357CJ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 357J — Introductory
Introductory 357J 1 Section 357JA contains provision about— a the charge to corporation tax on Northern Ireland profits and mainstream profits, and b the rate at which Northern Ireland profits are…
Section 357JJ — Restricted deduction: Northern Ireland rate lower than main rate
Restricted deduction: Northern Ireland rate lower than main rate 357JJ 1 The amount of the restricted deduction for a Northern Ireland loss for the purposes of section 357JC(2) or (4), 357JG(2) or…
Section 357LJ — Investment managers: disregard of certain chargeable profits
Investment managers: disregard of certain chargeable profits 357LJ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 357NJ — Losses
Losses 357NJ This Part applies in relation to the attribution of losses to a company's NI RE as it applies to the attribution of profits.
Section 357OJ — Assets representing production expenditure on films
Assets representing production expenditure on films 357OJ 1 In determining for the purposes of section 357OH(1) (pre-commencement asset) whether an asset representing production expenditure on a film…
Section 357UJ — Introduction and interpretation
Introduction and interpretation 357UJ 1 This Chapter makes provision about the operation of Part 15D of CTA 2009 (orchestra tax relief) in relation to expenditure incurred by a company in an…
Section 357YJ — Examples of results that may indicate exclusion not applicable
Examples of results that may indicate exclusion not applicable 357YJ 1 Each of the following is an example of something which might indicate that arrangements whose main purpose, or one of whose main…
Section 357BK — Marketing assets return figure
Marketing assets return figure 357BK 1 The marketing assets return figure for a relevant IP income sub-stream is— NMR − AMR where— NMR is the notional marketing royalty in respect of the sub-stream…
Section 357CK — Deductions that are not routine deductions
Deductions that are not routine deductions 357CK . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 357K — Application of Chapter
Application of Chapter 357K The definitions in this Chapter apply for the purposes of this Part.
Section 357LK — Miscellaneous
Miscellaneous 357LK 1 For the purposes of this Chapter a person is regarded as carrying out a transaction on behalf of another if the person— a undertakes the transaction, whether on behalf of or to…
Section 357NK — Trade includes office
Trade includes office 357NK In this Part, except so far as the context otherwise requires— a references to a trade include an office, and b references to carrying on a trade including holding an…
Section 357OK — Fungible assets
Fungible assets 357OK 1 This section and section 357OL have effect for the purposes of this Chapter in relation to assets to which section 858 of CTA 2009 (treatment of fungible assets) applies. 2…
Section 357UK — Northern Ireland additional deduction
Northern Ireland additional deduction 357UK 1 In this Chapter “ a Northern Ireland additional deduction ” means so much of a deduction under section 1217RD of CTA 2009 (claim for additional…
Section 357YK — Corporation tax rate on restitution interest
Corporation tax rate on restitution interest 357YK 1 Corporation tax is charged on restitution interest at the restitution payments rate. 2 The “restitution payments rate” is 45%.
Section 357BL — Introduction
Introduction 357BL 1 Sections 357BLA to 357BLH apply for the purpose of determining the R&D fraction for a relevant IP income sub-stream established at Step 2 in section 357BF(2) in determining the…
Section 357CL — Companies eligible to elect for small claims treatment
Companies eligible to elect for small claims treatment 357CL 1 A company may make an election under this section for small claims treatment for an accounting period if condition A or B is met in…
Section 357L — Northern Ireland regional establishments of companies
Northern Ireland regional establishments of companies 357L 1 A company has a Northern Ireland regional establishment (referred to in this Part as a “ NI RE ”) if (and only if)— a the company has a…
Section 357OL — Realisation and acquisition of fungible assets
Realisation and acquisition of fungible assets 357OL 1 Subsection (2) applies if— a a company realises a fungible asset, and b apart from section 357OK(2), the asset would be treated as part of a…
Section 357UL — Northern Ireland supplementary deduction
Northern Ireland supplementary deduction 357UL 1 This section applies where— a a company is entitled under section 1217RD of CTA 2009 to an additional deduction in calculating the profit or loss of…
Section 357YL — Exclusion of reliefs, set-offs etc
Exclusion of reliefs, set-offs etc 357YL 1 Under subsection (3) of section 4 (amounts to which rates of corporation tax applied) the amounts to be added together to find a company's “total profits”…
Section 357BM — Profits arising before grant of right
Profits arising before grant of right 357BM 1 This section applies where a company— a holds a right mentioned in paragraph (a), (b) or (c) of section 357BB(1) (rights to which this Part applies) or…
Section 357CM — Small claims amount
Small claims amount 357CM 1 This section applies where a company makes an election under section 357CL for small claims treatment for an accounting period. 2 The small claims amount in relation to…
Section 357M — Introductory
Introductory 357M 1 This Chapter applies to a company that is a Northern Ireland company in an accounting period by virtue of the SME (Northern Ireland employer) condition in section 357KA. 2 In this…
Section 357OM — Assets whose value derives from pre-commencement assets
Assets whose value derives from pre-commencement assets 357OM 1 This section applies if— a on or after the commencement day a company (“ the acquiring company ”) acquires an intangible fixed asset…
Section 357UM — Northern Ireland supplementary deduction: amount
Northern Ireland supplementary deduction: amount 357UM 1 This section contains provision for the purposes of section 357UL(2) about the amount of the Northern Ireland supplementary deduction. 2 If…
Section 357YM — Assignment of rights to person not chargeable to corporation tax
Assignment of rights to person not chargeable to corporation tax 357YM 1 Subsection (4) applies if— a a chargeable company (“the transferor”) transfers to a person who either— i is not a company, or…
Section 357BN — Small claims treatment
Small claims treatment 357BN 1 This section applies where— a a company carries on only one trade during an accounting period, b section 357BF applies for the purposes of determining the relevant IP…
Section 357CN — Marketing assets return figure
Marketing assets return figure 357CN 1 The marketing assets return figure in relation to a trade of a company for an accounting period is— NMR − AMR where— NMR is the notional marketing royalty in…
Section 357N — Introductory
Introductory 357N 1 This Chapter applies to a company that is a Northern Ireland company in an accounting period by virtue of the SME (election) condition or the large company condition in section…
Section 357ON — The pre-commencement status conditions
The pre-commencement status conditions 357ON 1 For the purposes of section 357OM(1) the other asset meets the pre-commencement status conditions if— a it was created before the commencement day, or b…
Section 357UN — Orchestra tax credit: Northern Ireland supplementary deduction ignored
Orchestra tax credit: Northern Ireland supplementary deduction ignored 357UN For the purpose of determining the available loss of a company under section 1217RH of CTA 2009 (amount of surrenderable…
Section 357YN — Migration of company with claim to restitution interest
Migration of company with claim to restitution interest 357YN 1 This section applies where— a restitution interest arises to a non-UK resident company, b the rights in respect of which the company is…
Section 357BO — Relevant IP profits
Relevant IP profits 357BO 1 Section 357BF applies, with the modifications set out in section 357BQ, for the purposes of determining the relevant IP profits of a trade of a company for an accounting…
Section 357CO — Notional marketing royalty
Notional marketing royalty 357CO 1 The notional marketing royalty in respect of a trade of a company for an accounting period is the appropriate percentage of the relevant IP income for that…