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Corporation Tax Act 2010

Sections and provisions with full text and the judgments that cite each one.

Section 162 — Meaning of “normal commercial loan”

Meaning of “normal commercial loan” 162 1 For the purposes of sections 158(1)(b) and 159(4)(b) “ normal commercial loan ” means a loan— a which is of or includes new consideration, and b in relation…

Section 163 — Normal commercial loans: company's results or value of assets

Normal commercial loans: company's results or value of assets 163 1 Interest is not within section 162(4)(a) by reason only that the terms of the loan provide for the rate of interest— a to be…

Section 164 — Sections 160 and 162: supplementary

Sections 160 and 162: supplementary 164 1 This subsection applies to any shares— a in relation to which conditions A, C, D and E in section 160 are met, and b which do not carry any rights to…

Section 164A — Loan forming part of tier two capital

Loan forming part of tier two capital 164A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Section 165 — Proportion of profits available for distribution to which company is entitled

Proportion of profits available for distribution to which company is entitled 165 1 This section applies for the purpose of determining the proportion to which a company (“company A”) is, at any…

Section 166 — Proportion of assets available for distribution to which company is entitled

Proportion of assets available for distribution to which company is entitled 166 1 This section applies for the purpose of determining the proportion to which a company (“company A”) would, at any…

Section 167 — Profits or assets available for distribution and entitlement: supplementary

Profits or assets available for distribution and entitlement: supplementary 167 1 References to profits or assets available for distribution to equity holders of a company do not include references…

Section 168 — Meaning of “the relevant accounting period”

Meaning of “the relevant accounting period” 168 1 For the purpose of determining the proportion of profits or assets to which company A would be beneficially entitled as mentioned in section 165(2)…

Section 169 — Application and interpretation of sections 170 to 182

Application and interpretation of sections 170 to 182 169 1 Sections 170 to 182 apply for the purpose of determining the proportion of profits or assets to which company A would be beneficially…

Section 170 — Shares or securities with limited rights

Shares or securities with limited rights 170 1 This section applies if, at the relevant time, one or more of the participating equity holders holds, as such, shares or securities with distribution…

Section 171 — Shares or securities with temporary rights

Shares or securities with temporary rights 171 1 Section 172 applies if, at the relevant time, one or more of the participating equity holders holds, as such, shares or securities— a which have…

Section 172 — Company A's proportion if shares etc have temporary rights

Company A's proportion if shares etc have temporary rights 172 1 If this section applies, determine what company A's proportion would be if the rights of all participating equity holders at the…

Section 173 — Cases in which option arrangements are in place

Cases in which option arrangements are in place 173 1 Section 174 applies if option arrangements are in place at the relevant time. 2 “ Option arrangements ” means arrangements in relation to which…

Section 174 — Company A's proportion if option arrangements in place

Company A's proportion if option arrangements in place 174 1 If this section applies, take the following steps. Step 1 Identify all option rights under the option arrangements (or sets of…

Section 174A — Certain option arrangements not within section 173

Certain option arrangements not within section 173 174A 1 Arrangements entered into by a joint venture company which, apart from this section, would be option arrangements within section 173 are not…

Section 174B — Certain mortgage arrangements not within section 173

Certain mortgage arrangements not within section 173 174B 1 Arrangements entered into by a company which, apart from this section, would be option arrangements within section 173 are not to be…

Section 175 — Cases in which both sections 170 and 172 apply

Cases in which both sections 170 and 172 apply 175 1 This section applies in a case in which sections 170 and 172 apply but section 174 does not. 2 Determine what company A's proportion would be— a…

Section 176 — Cases in which both sections 170 and 174 apply

Cases in which both sections 170 and 174 apply 176 1 This section applies in a case in which sections 170 and 174 apply but section 172 does not. 2 Determine what company A's proportion would be— a…

Section 177 — Cases in which both sections 172 and 174 apply

Cases in which both sections 172 and 174 apply 177 1 This section applies in a case in which sections 172 and 174 apply but section 170 does not. 2 Determine what company A's proportion would be— a…

Section 178 — Cases in which sections 170, 172 and 174 all apply

Cases in which sections 170, 172 and 174 all apply 178 1 This section applies in a case in which sections 170, 172 and 174 all apply. 2 Determine what company A's proportion would be— a on the basis…

Section 179 — Cases in which surrendering or claimant company is non-UK resident

Cases in which surrendering or claimant company is non-UK resident 179 1 If the surrendering company or the claimant company is non-UK resident at the relevant time, section 180 applies as mentioned…

Section 180 — Company A's proportion if non-UK resident involved

Company A's proportion if non-UK resident involved 180 1 If this section applies— a go to subsection (2) if the case is one in which none of sections 170, 172 and 174 applies, and b go to subsection…

Section 181 — Assumptions to be applied if non-UK resident company involved

Assumptions to be applied if non-UK resident company involved 181 1 The assumptions referred to in section 180 are as follows. Assumption 1 The profit distribution or the distribution on the notional…

Section 182 — Assets etc referable to UK trade

Assets etc referable to UK trade 182 Profits, assets or liabilities of company B are referable to company B's UK trade so far as they— a are attributable to, or used for the purposes of, activities…

Section 183 — Payments for group relief

Payments for group relief 183 1 This section applies if— a the surrendering company and the claimant company have an agreement between them in relation to losses and other amounts of the surrendering…

Section 184 — References to “allowance” in CAA 2001

References to “allowance” in CAA 2001 184 References in CAA 2001 (apart from Parts 6 and 10) to an allowance include references to an allowance which would be made— a but for the giving of group…

Section 185 — “Trading company” and “holding company”

“Trading company” and “holding company” 185 1 In this Part “ trading company ” means a company the business of which consists wholly or mainly in the carrying on of a trade or trades. 2 In this Part…

Section 186 — When activities of a company are double taxation exempt

When activities of a company are double taxation exempt 186 1 For the purposes of this Part activities of a company are double taxation exempt for an accounting period if, because of double taxation…

Section 187 — “Non-UK tax”

“Non-UK tax” 187 1 In this Part “ non-UK tax ” means a tax chargeable under the law of a territory outside the United Kingdom which— a is charged on income and corresponds to United Kingdom income…

Section 188 — Other definitions

Other definitions 188 1 In this Part— “ the claimant company ” has the meaning given by section 130(2) ..., “ the claim period ” has the meaning given by section 130(2) ..., “ company ” means any…

Section 188AA — Introduction to Part

Introduction to Part 188AA 1 This Part— a allows a company to surrender losses and other amounts that have been carried forward to an accounting period of the company (see Chapter 2), and b enables,…

Section 188BA — Overview of Chapter

Overview of Chapter 188BA 1 This Chapter allows a company to surrender losses and other amounts that have been carried forward to an accounting period of the company. 2 Section 188BB sets out the…

Section 188CA — Overview of Chapter

Overview of Chapter 188CA This Chapter sets out how a company may claim group relief for carried-forward losses and how the relief is given.

Section 188DA — Overview

Overview 188DA This Chapter sets out limitations on the amount of relief which may be given on a claim under section 188CB.

Section 188EA — Overview of Chapter

Overview of Chapter 188EA This Chapter sets out limitations on the amount of relief which may be given on a claim under section 188CC.

Section 188FA — Payments for group relief for carried-forward losses

Payments for group relief for carried-forward losses 188FA 1 This section applies if— a the surrendering company and the claimant company have an agreement between them in relation to losses and…

Section 188BB — Surrender of carried-forward losses and other amounts

Surrender of carried-forward losses and other amounts 188BB 1 Subsection (2) applies if— a a loss or other amount is carried forward to an accounting period of a company under any of the following…

Section 188CB — Claims in relation to all the surrenderable amounts

Claims in relation to all the surrenderable amounts 188CB 1 This section applies in relation to the surrendering company's surrenderable amounts for the surrender period under Chapter 2. 2 If the…

Section 188DB — Limitation on amount of relief applying to all claims under section 188CB

Limitation on amount of relief applying to all claims under section 188CB 188DB 1 The amount of group relief for carried-forward losses to be given on a claim under section 188CB (“the current…

Section 188EB — Limitation on amount of relief applying to all claims under section 188CC

Limitation on amount of relief applying to all claims under section 188CC 188EB 1 The amount of group relief for carried-forward losses to be given on a claim under section 188CC (“the current…

Section 188FB — Subsidiaries, groups and consortiums

Subsidiaries, groups and consortiums 188FB Chapter 5 of Part 5 (which explains certain key concepts for the purposes of Part 5, including (in particular) how to determine if a company is a member of…

Section 188BC — Restriction on surrendering pre-1 April 2017 losses etc

Restriction on surrendering pre-1 April 2017 losses etc 188BC 1 The surrendering company may not surrender under this Chapter— a a loss carried forward to the surrender period under section 753(3) of…

Section 188CC — Claims in relation to the surrenderable amounts that are attributable to a specified accounting period

Claims in relation to the surrenderable amounts that are attributable to a specified accounting period 188CC 1 This section applies in relation to the surrendering company's surrenderable amounts for…

Section 188DC — Unused part of the surrenderable amounts

Unused part of the surrenderable amounts 188DC 1 The unused part of the surrenderable amounts is the amount equal to— a the surrenderable amount for the overlapping period (see subsection (2)), less…

Section 188EC — Unused part of surrenderable amounts attributable to specified loss-making period

Unused part of surrenderable amounts attributable to specified loss-making period 188EC 1 The unused part of the surrenderable amounts that are attributable to the specified loss-making period is the…

Section 188FC — “Trading company” and “holding company”

“Trading company” and “holding company” 188FC 1 In this Part “ trading company ” means a company the business of which consists wholly or mainly in the carrying on of a trade. 2 In this Part “…

Section 188BD — Restriction where investment business has become small or negligible

Restriction where investment business has become small or negligible 188BD 1 The surrendering company may not surrender under this Chapter— a a loss carried forward to the surrender period under…

Section 188CD — Claim not allowed by company with unused carried-forward losses of its own

Claim not allowed by company with unused carried-forward losses of its own 188CD A company may not make a claim for group relief for carried-forward losses for an accounting period if— a any amount…

Section 188DD — Claimant company's relevant maximum for overlapping period

Claimant company's relevant maximum for overlapping period 188DD 1 The claimant company's relevant maximum for the overlapping period is determined as follows— Step 1 Calculate the claimant company's…

Section 188ED — Claimant company's relevant maximum for the overlapping period

Claimant company's relevant maximum for the overlapping period 188ED 1 The claimant company's relevant maximum for the overlapping period is determined as follows— Step 1 Calculate the claimant…