Corporation Tax Act 2010
Sections and provisions with full text and the judgments that cite each one.
Section 724A — Disregard of change in parent company
Disregard of change in parent company 724A 1 Where a new company (“N”) acquires all the issued share capital of another company (“C”), the resulting ownership change is disregarded for the purposes…
Section 725 — Provision applying for the purposes of Chapters 2 to 5A
Provision applying for the purposes of Chapters 2 to 5A 725 1 This section applies for the purposes of Chapters 2 to 5A . 2 If any of those Chapters has operated to restrict relief by reference to a…
Section 726 — Interpretation of Chapter
Interpretation of Chapter 726 In this Chapter— “ ownership ” means beneficial ownership (and references to acquisition and shareholder are construed accordingly), and “ shares ” includes stock.
Section 727 — Extended time limit for assessment
Extended time limit for assessment 727 If the operation of any provision in Chapters 2 to 6 depends on circumstances or events at a time or times after (but not more than 5 years after) a change in…
Section 728 — Provision of information about ownership of shares etc
Provision of information about ownership of shares etc 728 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 729 — Meaning of “company with investment business”
Meaning of “company with investment business” 729 In this Part “ company with investment business ” has the meaning given by section 1218B of CTA 2009.
Section 730 — Meaning of “relevant non-trading debit”
Meaning of “relevant non-trading debit” 730 1 This section applies for the purposes of sections 679 , 696 and 705C . 2 “ Relevant non-trading debit ” means a non-trading debit within subsection (3),…
Section 730A — Overview
Overview 730A 1 This Part makes provision restricting the circumstances in which deductible amounts may be brought into account where there has been a qualifying change in relation to a company. 2…
Section 730B — Interpretation of Part
Interpretation of Part 730B 1 In this Part— “ arrangements ” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable), “ deductible…
Section 730C — Disallowance of deductible amounts: relevant claims
Disallowance of deductible amounts: relevant claims 730C 1 This section applies where a relevant claim is made for an accounting period ending on or after the relevant day. 2 “ Relevant claim ” means…
Section 730D — Disallowance of deductible amounts: profit transfers
Disallowance of deductible amounts: profit transfers 730D 1 This section applies where arrangements (“the profit transfer arrangements”) are made which result in— a an increase in the total profits…
Section 730E — Overview
Overview 730E 1 This Part makes provision restricting the circumstances in which a company may make a deduction in respect of a relevant carried-forward loss. 2 For the meaning of “relevant…
Section 730F — Meaning of “relevant carried-forward loss”
Meaning of “relevant carried-forward loss” 730F 1 In this Part “ relevant carried-forward loss ” means any of the following— a a carried-forward trading loss (see subsection (2)), aa a…
Section 730G — Disallowance of deductions for relevant carried-forward losses
Disallowance of deductions for relevant carried-forward losses 730G 1 This section applies if conditions A to E are met. 2 Condition A is that— a for the purposes of corporation tax a company has…
Section 730H — Interpretation of section 730G
Interpretation of section 730G 730H 1 In section 730G— “ arrangements ” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable); “…
Section 731 — Overview of Part
Overview of Part 731 1 This Part makes provision for counteracting corporation tax advantages obtained or obtainable by companies to which section 733 applies in respect of a transaction or…
Section 732 — Meaning of “corporation tax advantage”
Meaning of “corporation tax advantage” 732 1 In this Part “ corporation tax advantage ” means— a a relief from corporation tax or increased relief from corporation tax, b a repayment of corporation…
Section 733 — Company liable to counteraction of corporation tax advantage
Company liable to counteraction of corporation tax advantage 733 1 This section applies to a company in respect of a transaction in securities or two or more such transactions if the company is in a…
Section 734 — Exception where no tax avoidance object shown
Exception where no tax avoidance object shown 734 1 Section 733 does not apply to a company in respect of a transaction in securities or two or more such transactions if the company shows that the…
Section 735 — Abnormal dividends used for exemptions or reliefs (circumstance A)
Abnormal dividends used for exemptions or reliefs (circumstance A) 735 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Section 736 — Receipt of consideration representing company's assets, future receipts or trading stock (circumstance C)
Receipt of consideration representing company's assets, future receipts or trading stock (circumstance C) 736 1 This section applies in relation to a company (“A”) if subsections (2) to (4) apply. 2…
Section 737 — Receipt of consideration in connection with relevant company distribution (circumstance D)
Receipt of consideration in connection with relevant company distribution (circumstance D) 737 1 This section applies in relation to a company (“the section 733 company”) if subsections (2) to (4)…
Section 738 — Receipt of assets of relevant company (circumstance E)
Receipt of assets of relevant company (circumstance E) 738 1 This section applies in relation to a company (“the section 733 company”) if subsections (2) to (4) and (7) apply. 2 The section 733…
Section 739 — Meaning of “relevant company” in sections 737 and 738
Meaning of “relevant company” in sections 737 and 738 739 1 A company is a relevant company for the purposes of sections 737 and 738 if it is— a a company under the control of not more than 5 persons…
Section 740 — Abnormal dividends: general
Abnormal dividends: general 740 1 An amount received by way of dividend is treated as abnormal for the purposes of this Part if the appropriate authority is satisfied— a in any case that the…
Section 741 — Abnormal dividends: the excessive return condition
Abnormal dividends: the excessive return condition 741 1 The excessive return condition is that the dividend substantially exceeds a normal return on the consideration provided by the recipient for…
Section 742 — Abnormal dividends: the excessive accrual condition
Abnormal dividends: the excessive accrual condition 742 1 The excessive accrual condition is that the dividend substantially exceeds the amount which the recipient would have received if— a the…
Section 743 — Preliminary notification that section 733 may apply
Preliminary notification that section 733 may apply 743 1 An officer of Revenue and Customs must notify a company if the officer has reason to believe that— a section 733 (company liable to…
Section 744 — Opposed notifications: statutory declarations
Opposed notifications: statutory declarations 744 1 If a company on which a notification is served under section 743 is of the opinion that section 733 (company liable to counteraction of corporation…
Section 745 — Opposed notifications: determinations by tribunal
Opposed notifications: determinations by tribunal 745 1 This section applies if the officer of Revenue and Customs receiving a statutory declaration under section 744(1) sees reason to take further…
Section 746 — Counteraction notices
Counteraction notices 746 1 If— a a company on which a notification is served under section 743 does not send a statutory declaration to an officer of Revenue and Customs under section 744 within 30…
Section 747 — Timing of assessments in section 738 cases
Timing of assessments in section 738 cases 747 1 This section applies if section 733 (company liable to counteraction of corporation tax advantage) applies to a company because it is in a position to…
Section 748 — Application for clearance of transactions
Application for clearance of transactions 748 1 A company may provide the Commissioners for Her Majesty's Revenue and Customs with particulars of a transaction or transactions effected or to be…
Section 749 — Effect of clearance notification under section 748
Effect of clearance notification under section 748 749 1 This section applies if the Commissioners for Her Majesty's Revenue and Customs notify a company under section 748 that they are satisfied…
Section 750 — Appeals against counteraction notices
Appeals against counteraction notices 750 1 A company on which a counteraction notice has been served may appeal on the grounds that— a section 733 (company liable to counteraction of corporation tax…
Section 751 — Interpretation of Part
Interpretation of Part 751 1 In this Part— “ company ” includes any body corporate, “ dividends ” includes references to other ... distributions and to interest, “securities”— includes shares and…
Section 752 — Application of Chapter
Application of Chapter 752 1 This Chapter applies if— a a company within the charge to corporation tax (“ the transferor ”) makes a transfer to another person (“ the transferee ”) of a right to…
Section 753 — Value of transferred income stream treated as income
Value of transferred income stream treated as income 753 1 The relevant amount (see subsection (2)) is to be treated as income of the transferor chargeable to corporation tax in the same way and to…
Section 754 — Exception: amount otherwise taxed
Exception: amount otherwise taxed 754 This Chapter does not apply if and to the extent that the income under section 753(1) is (apart from this Chapter)— a charged to tax as income of the transferor,…
Section 755 — Exception: transfer by way of security
Exception: transfer by way of security 755 1 This Chapter does not apply if— a the consideration for the transfer is the advance under a type 1 finance arrangement, and b the transferor is, or is a…
Section 756 — Partnership shares
Partnership shares 756 1 For the purposes of this Chapter a transfer of a right to relevant receipts consisting of the reduction in the transferor's share in the profits or losses of a partnership is…
Section 757 — Interpretation of Chapter
Interpretation of Chapter 757 1 For the purposes of this Chapter— a the grant or surrender of a lease of land is to be regarded as a transfer of the land, b the disposal of an interest in an oil…
Section 757A — Application of Chapter
Application of Chapter 757A 1 This Chapter applies if directly or indirectly in consequence of, or otherwise in connection with, arrangements involving a company within the charge to corporation tax…
Section 757B — Relevant amount to be treated as income
Relevant amount to be treated as income 757B 1 The relevant amount is to be treated as income of the transferor chargeable to corporation tax in the same way and to the same extent as that in which…
Section 758 — Type 1 finance arrangement defined
Type 1 finance arrangement defined 758 1 For the purposes of this Chapter an arrangement is a type 1 finance arrangement if conditions A and B are met. 2 Condition A is that under the arrangement— a…
Section 759 — Certain tax consequences not to have effect
Certain tax consequences not to have effect 759 1 This section applies if a type 1 finance arrangement would have the relevant effect (ignoring this section). 2 The arrangement is not to have that…
Section 760 — Payments treated as borrower's income
Payments treated as borrower's income 760 1 This section applies if— a a type 1 finance arrangement would not have the relevant effect (ignoring section 759(2)), b that arrangement would not have the…
Section 761 — Deemed loan relationship if borrower is a company
Deemed loan relationship if borrower is a company 761 1 This section applies if— a there is a type 1 finance arrangement, b the borrower is a company, and c either— i the arrangement is prevented by…
Section 762 — Deemed loan relationship if borrower is partnership with corporate member
Deemed loan relationship if borrower is partnership with corporate member 762 1 This section applies if— a there is a type 1 finance arrangement, b the borrower is a partnership, and c either— i the…
Section 763 — Type 2 finance arrangement defined
Type 2 finance arrangement defined 763 1 For the purposes of this Chapter an arrangement is a type 2 finance arrangement if conditions A and B are met. 2 Condition A is that— a under the arrangement…