(1) If a company with investment business receives a payment by way of a grant under—
(a) section 7 or 8 of the Industrial Development Act 1982 (c. 52), or
(b) Article 7, 9 or 30 of the Industrial Development (Northern Ireland) Order 1982 (S.I. 1982/1083 (N.I. 15)),
the payment is to be treated as an amount to which the charge to corporation tax on income applies.
(2) Subsection (1) does not apply if—
(a) the grant is designated as made towards the cost of specified capital expenditure,
(b) the grant is designated as compensation for the loss of capital assets, or
(c) the grant is for all or part of a corporation tax liability (including one that has already been met).
(3) Tax is not charged under this section if the payment is taken into account (under another provision) in calculating profits for corporation tax purposes.
1253 Contributions to local enterprise organisations or urban regeneration companies: disqualifying benefits
(1) This section applies if—
(a) a deduction has been made under section 1219 by virtue of section 1244 (contributions to local enterprise agencies or urban regeneration companies: expenses of management), and
(b) the contributor or a connected person receives a disqualifying benefit that is in any way attributable to the contribution.
(2) The contributor is to be treated as receiving, when the benefit is received, an amount—
(a) which is equal to the value of the benefit (so far as not brought into account in determining the amount of the deduction), and
(b) to which the charge to corporation tax on income applies.
(3) In this section “disqualifying benefit” has the same meaning as in section 1244.
1253A Contributions to flood and coastal erosion risk management projects: refunds etc
(1) This section applies if—
(a) a deduction has been made under section 1219 by virtue of section 1244A (contributions to flood and coastal erosion risk management projects: expenses of management), and
(b) the contributor or a connected person receives—
(i) a refund of any part of the contribution, if the contribution is a sum of money, or
(ii) compensation for any part of the contribution, if the contribution is the provision of services,
in money or money's worth.
(2) The contributor is to be treated as receiving, when the refund or compensation is received, an amount—
(a) which is equal to so much of the refund or compensation, or so much of the value of the refund or compensation, as is not otherwise taken into account for corporation tax purposes, and
(b) to which the charge to corporation tax on income applies.
(1) If as a result of a repayment provision a payment—
(a) is made to a company with an investment business, and
(b) is not brought into account as a receipt of a trade under section 104, or as a receipt of a property business as a result of section 210,
the payment is to be treated as an amount to which the charge to corporation tax on income applies.
(2) In this section “repayment provision” means—
(a) any provision made by virtue of section 136(7) or 214(1)(e) of FISMA 2000, or
(b) any provision made by scheme rules for fees to be refunded in specified circumstances.
(3) In this section “scheme rules” means the rules referred to in paragraph 14(1) of Schedule 17 to FISMA 2000.
(1) Any reference in sections 1225 to 1227 to expenses of management being debited in accounts is to those expenses being brought into account as a debit in—
(a) the company's profit and loss account or income statement, or
(b) a statement of total recognised gains and losses, statement of changes in equity or other statement of items brought into account in calculating the company's profits and losses for accounting purposes.
(2) In section 1229(1) “brought into account” means brought into account in—
(a) the company's profit and loss account or income statement, or
(b) a statement of total recognised gains and losses, statement of changes in equity or other statement of items brought into account in calculating the company's profits and losses for accounting purposes.
(3) In this Part—
“credit” means an amount which for accounting purposes increases or creates a profit, or reduces a loss, for a period of account, and
“debit” means an amount which for accounting purposes reduces a profit, or increases or creates a loss, for a period of account.
(1) This Part contains some special rules about partnerships.
(2) For restrictions that in some circumstances affect relief for losses, and certain other reliefs, for a company that is a member of a partnership see Chapter 3 of Part 22 of CTA 2010 (transfer of relief within partnerships).
(1) In this Act persons carrying on a trade in partnership are referred to collectively as a “firm”.
(2) This section and sections 1259 to 1266 are expressed to apply to trades, but unless otherwise indicated (whether expressly or by implication) also apply to businesses that are not trades.
(3) In those sections as applied by subsection (2)—
(a) references to a trade are references to a business, and
(b) references to the profits of a trade are references to the income arising from a business.
Unless otherwise indicated (whether expressly or by implication), a firm is not to be regarded for corporation tax purposes as an entity separate and distinct from the partners.
(1) This section applies if—
(a) a partner in a firm is partner as trustee for a beneficiary who is absolutely entitled to the partner's share of the profits of the firm, and
(b) the beneficiary is chargeable to tax on those profits.
(2) References in this Part to a partner or member of the firm include references to the beneficiary.
(1) This section applies if a firm carries on a trade and any partner in the firm (“the partner”) is a company within the charge to corporation tax.
(2) For any accounting period of the firm, the amount of the profits of the trade (“the amount of the firm's profits”) is taken to be the amount determined, in relation to the partner, in accordance with subsection (3) or (4).
(3) If the partner is UK resident—
(a) determine what would be the amount of the profits of the trade chargeable to corporation tax for that period if a UK resident company carried on the trade, and
(b) take that to be the amount of the firm's profits.
(4) If the partner is non-UK resident—
(a) determine what would be the amount of the profits of the trade chargeable to corporation tax for that period if a non-UK resident company carried on the trade, and
(b) take that to be the amount of the firm's profits.
(5) The amount of any losses of the trade for an accounting period of the firm is calculated, in relation to the partner, in the same way as the amount of any profits.
(6) This section is subject to section 1260.
(1) In determining under section 1259 the profits of a trade for any accounting period no account is taken of any losses for another accounting period.
(2) Profits and losses are determined under section 1259 on the basis that no interest paid or other distribution made by the firm is a distribution for the purposes of section 1305(1) (which provides that no deduction is allowed for dividends or other distributions).
(1) In this Part references to an accounting period of a firm which carries on a trade are to a period that would be an accounting period of the firm if the firm were a company.
(2) For the purposes of subsection (1) it is to be assumed that the company by reference to which the accounting periods of the firm are determined (“the deemed company”)—
(a) is UK resident,
(b) acquires a source of income on the occurrence of an event that falls within subsection (3),
(c) ceases to trade on the occurrence of an event that falls within subsection (4), and
(d) ceases to trade, and immediately afterwards starts to trade, on the occurrence of a change in the persons carrying on the trade falling within subsection (5).
Paragraph (a) is subject to subsection (6).
(3) An event falls within this subsection if—
(a) immediately before the event no company carries on the trade in partnership, and
(b) immediately after the event the trade is carried on in partnership by persons who include a company.
(4) An event falls within this subsection if—
(a) immediately before the event the trade is carried on in partnership by persons who include a company, and
(b) immediately after the event no company carries on the trade in partnership.
(5) A change in the persons carrying on the trade falls within this subsection if—
(a) both immediately before and immediately after the change the trade is carried on in partnership by persons who include a company, but
(b) no company which carried on the trade immediately before the change continues to carry it on after the change.
(6) For the purpose of determining, in relation to a partner, the accounting periods by reference to which profits are to be calculated under section 1259, the residence of the deemed company at any time is to be taken to be the same as the partner's.
1262 Allocation of firm's profits or losses between partners
(1) For any accounting period of a firm a partner's share of a profit or loss of a trade carried on by the firm is determined for corporation tax purposes in accordance with the firm's profit-sharing arrangements during that period.
This is subject to sections 1263 to 1264A and section 12ABZB of TMA 1970 (partnership return is conclusive).
(2) If a firm makes qualifying charitable donations, a partner's share of the donations is determined for corporation tax purposes in accordance with the firm's profit-sharing arrangements during the accounting period of the firm in which the donations are made.
(3) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(4) In this section and sections 1263 and 1264 “profit-sharing arrangements” means the rights of the partners to share in the profits of the trade and the liabilities of the partners to share in the losses of the trade.
1263 Profit-making period in which some partners have losses
(1) For any accounting period of a firm, if—
(a) the calculation under section 1259 in relation to a partner (“company A”) produces a profit, and
(b) company A's share determined under section 1262 is a loss,
company A's share of the profit of the trade is neither a profit nor a loss.
(2) For any accounting period of a firm, if—
(a) the calculation under section 1259 in relation to company A produces a profit,
(b) company A's share determined under section 1262 is a profit, and
(c) the comparable amount for at least one other partner is a loss,
company A's share of the profit of the trade is the amount produced by the formula in subsection (3).
(3) The formula is—
FP
×
PP
PP
+
TCP
where—
FP is the amount of the firm's profit calculated under section 1259 in relation to company A,
PP is the amount determined under section 1262 to be company A's profit, and
TCP is the total of the comparable amounts attributed to other partners under Step 3 in subsection (4) that are profits.
(4) The comparable amount for each partner other than company A is determined as follows.
Step 1
Take the firm's profit calculated under section 1259 in relation to company A.
Step 2
Determine in accordance with the firm's profit-sharing arrangements during the relevant accounting period the shares of that profit that are attributable to each of the other partners.
Step 3
Each such share is the comparable amount for the partner to whom it is attributed.
(5) In subsections (2) to (4) “partner” means any partner in the firm, whether or not within the charge to corporation tax.
1264 Loss-making period in which some partners have profits
(1) For any accounting period of a firm, if—
(a) the calculation under section 1259 in relation to a partner (“company A”) produces a loss, and
(b) company A's share determined under section 1262 is a profit,
company A's share of the loss of the trade is neither a profit nor a loss.
(2) For any accounting period of a firm, if—
(a) the calculation under section 1259 in relation to company A produces a loss,
(b) company A's share determined under section 1262 is a loss, and
(c) the comparable amount for at least one other partner is a profit,
company A's share of the loss of the trade is the amount produced by the formula in subsection (3).
(3) The formula is—
FL
×
PL
PL
+
TCL
where—
FL is the amount of the firm's loss calculated under section 1259 in relation to company A,
PL is the amount determined under section 1262 to be company A's loss, and
TCL is the total of the comparable amounts attributed to other partners under Step 3 in subsection (4) that are losses.
(4) The comparable amount for each partner other than company A is determined as follows.
Step 1
Take the firm's loss calculated under section 1259 in relation to company A.
Step 2
Determine in accordance with the firm's profit-sharing arrangements during the relevant accounting period the shares of that loss that are attributable to each of the other partners.
Step 3
Each such share is the comparable amount for the partner to whom it is attributed.
(5) In subsections (2) to (4) “partner” means any partner in the firm, whether or not within the charge to corporation tax.
1264A Excess profit allocation to non-individual partners etc
(1) Subsection (2) applies in a case in which—
(a) section 850C(4) or 850D(4) of ITTOIA 2005 applies for a period of account (“the relevant period of account”), and
(b) the partner who is “B” for the purposes of section 850C or 850D of that Act (as the case may be) is a company.
(2) In applying sections 1262 to 1264 in relation to the company—
(a) for the accounting period of the firm which coincides with the relevant period of account, or
(b) if no accounting period of the firm coincides with the relevant period of account, for accounting periods of the firm in which the relevant period of account falls,
such adjustments are to be made as are just and reasonable to take account of the increase under section 850C(4) of ITTOIA 2005 or A's share of the firm's profit under section 850D(4) of that Act.
(3) Sections 850C(23) and 850E(2) of ITTOIA 2005 apply for corporation tax purposes as they apply for income tax purposes.
1265 Apportionment of profit share between partner's accounting periods
(1) This section applies if—
(a) a share of a profit or loss calculated for an accounting period of a firm is allocated to a company under any of sections 1262 to 1264, and
(b) the accounting period of the firm does not coincide with an accounting period of the company.
(2) The share of the profit or loss must be apportioned between the accounting periods of the company in which the accounting period of the firm falls.
1266 Resident partners and double taxation agreements
(1) This section applies if—
(a) a UK resident company (“the partner”) is a member of a firm which—
(i) resides outside the United Kingdom, or
(ii) carries on a trade the control and management of which is outside the United Kingdom, and
(b) by virtue of any arrangements having effect under section 2(1) of TIOPA 2010 (“the arrangements”) any of the income of the firm is relieved from corporation tax in the United Kingdom.
(2) The partner is liable to corporation tax on the partner's share of the income of the firm despite the arrangements.
(3) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(4) For the purposes of this section the members of a firm include any company which is entitled to a share of the income of the firm.
1267 Various rules for trades and property businesses
(1) In the case of a trade or property business carried on by a firm, the amount of any adjustment under—
(a) Chapter 14 of Part 3 (adjustment on change of basis: trades), or
(b) section 262 (giving effect to positive and negative adjustments: property businesses),
is calculated as if the firm were a UK resident company.
(2) Each partner's share of any amount brought into account as a receipt under Chapter 14 of Part 3, or section 262, is determined according to the firm's profit-sharing arrangements for the 12 months ending immediately before the date on which the new basis was adopted.
(3) A change in the persons carrying on a trade from one period of account to the next does not prevent Chapter 14 of Part 3 applying in relation to the trade so long as a company carrying on the trade in partnership immediately before the change continues to carry it on in partnership after the change.
(4) A change in the persons carrying on a property business from one period of account to the next does not prevent section 262 applying (by virtue of section 261) in relation to the property business so long as a company carrying on the property business in partnership immediately before the change continues to carry it on in partnership after the change.
(5) Sections 1259 to 1264 do not apply so far as subsection (1) or (2) applies.
1268 Election for spreading under Chapter 14 of Part 3
(1) A change in the persons carrying on a trade does not constitute the permanent cessation of the trade for the purposes of section 186 (mark to market: election for spreading) so long as a company carrying on the trade in partnership immediately before the change continues to carry it on in partnership after the change.
(2) Any election under section 186 must be made jointly by all the persons who have been members of the firm in the period of 12 months ending immediately before the date on which the new basis was adopted.
In sections 1267 and 1268—
(a) “profit-sharing arrangements” means the rights of the partners to share in the profits of the trade or property business (as the case requires), and
(b) references to the date on which the new basis was adopted are to the first day of the first period of account for which it was adopted.
1270 Special provisions about farming and property income
(1) The rule in section 36(2) (farming trades) operates in relation to firms so that—
(a) all farming in the United Kingdom which a firm carries on, other than farming carried on as part of another trade, is treated as one trade, but
(b) the farming carried on by a firm which is treated as one trade is not included in any farming trade of any partner in the firm.
(2) Section 205 (UK property business) operates in relation to firms so that—
(a) every business and transaction mentioned in that section carried on, or entered into, by a firm constitutes the firm's UK property business, but
(b) each business or transaction included in the firm's UK property business is not included in any UK property business of any partner in the firm.
(3) Section 206 (overseas property business) operates in relation to firms so that—
(a) every business and transaction mentioned in that section carried on, or entered into, by a firm constitutes the firm's overseas property business, but
(b) each business or transaction included in the firm's overseas property business is not included in any overseas property business of any partner in the firm.
1271 Sale of patent rights: effect of partnership changes
(1) This section applies if each of the following conditions is met—
(a) a person (“the trader”) sells the whole or part of any patent rights in carrying on a trade,
(b) tax is chargeable under section 912 of this Act or section 587 of ITTOIA 2005 on the proceeds of the sale or on any instalment of those proceeds,
(c) the tax is chargeable in one or more accounting periods or tax years (referred to in this section as “the tax charge periods”),
(d) there is a change in the persons carrying on the trade at any time between the beginning of the first of those tax charge periods and the end of the last of them, and
(e) the partnership condition and the continuity condition are met.
(2) The partnership condition is that—
(a) the trader is a firm at the time of the sale, or
(b) the trade is carried on in partnership at any time between the beginning of the first of the tax charge periods and the end of the last of them.
(3) The continuity condition is—
(a) in the case of an amount chargeable under section 912, that a company which carried on the trade in partnership immediately before the change continues to carry it on in partnership after the change, or
(b) in the case of an amount chargeable under section 587 of ITTOIA 2005, that a person who carried on the trade immediately before the change continues to carry it on after the change.
(4) Any amounts chargeable in respect of the proceeds or instalment that would (apart from this section) be treated in accordance with Chapter 3 of Part 9 of this Act or Chapter 2 of Part 5 of ITTOIA 2005 as profits of the seller of the patent rights chargeable in tax charge periods falling wholly after the change are treated for corporation tax purposes—
(a) as proceeds, arising at a constant daily rate during the remainder of the relevant period, of a sale of patent rights by the person or persons carrying on the trade after the change, and
(b) if the trade is carried on in partnership after the change, as arising to the partners in shares calculated in accordance with the firm's profit-sharing arrangements.
(5) If the change occurs during the course of a tax charge period—
(a) any company that would, but for this section, have been charged to corporation tax in that period on a sum (“S”) in respect of the proceeds or instalment is so charged on a fraction of S proportionate to the length of the part of the period before the change, and
(b) the balance of S not dealt with under paragraph (a) is treated for the purposes of this section and section 861 of ITTOIA 2005 (sale of patent rights: effect of partnership changes) as if it were an amount such as is described in subsection (4).
(6) In this section “the remainder of the relevant period” means—
(a) if one or more tax charge periods begins after the tax charge period in which the change occurs, the period beginning immediately after the change and ending 6 years after the beginning of the first of the tax charge periods, or
(b) otherwise, the period beginning immediately after the change and ending at the end of the tax charge period in which the change occurs.
(7) In this section “profit-sharing arrangements” means the rights of the partners to share in the profits of the trade.
1272 Sale of patent rights: effect of later cessation of trade
(1) This section applies if—
(a) a person sells the whole or part of any patent rights in carrying on a trade,
(b) by virtue of section 1271 amounts are chargeable to corporation tax under section 912 as profits of one or more companies for the time being carrying on the trade in partnership,
(c) a partner which is a company ceases to carry on the trade after that, and
(d) no company which carried on the trade immediately before the cessation continues to carry on the trade in partnership immediately after the cessation.
(2) Any amounts mentioned in subsection (1)(b) which would have been chargeable in any accounting period of a company later than that in which the cessation occurred are charged in the accounting period of the company in which the cessation occurred.
(1) For corporation tax purposes, if a limited liability partnership carries on a trade or business with a view to profit—
(a) all the activities of the limited liability partnership are treated as carried on in partnership by its members (and not by the limited liability partnership as such),
(b) anything done by, to or in relation to the limited liability partnership for the purposes of, or in connection with, any of its activities is treated as done by, to or in relation to the members as partners, and
(c) the property of the limited liability partnership is treated as held by the members as partnership property.
References in this subsection to the activities of the limited liability partnership are to anything that it does, whether or not in the course of carrying on a trade or business with a view to profit.
(2) For all purposes, except as otherwise provided, in the Corporation Tax Acts—
(a) references to a firm include a limited liability partnership in relation to which subsection (1) applies,
(b) references to members of a firm include members of such a limited liability partnership,
(c) references to a company do not include such a limited liability partnership, and
(d) references to members of a company do not include members of such a limited liability partnership.
(3) Subsection (1) continues to apply in relation to a limited liability partnership which no longer carries on any trade or business with a view to profit—
(a) if the cessation is only temporary, or
(b) during a period of winding up following a permanent cessation, provided that—
(i) the winding up is not for reasons connected in whole or in part with the avoidance of tax, and
(ii) the period of winding up is not unreasonably prolonged.
This is subject to subsection (4).
(4) Subsection (1) ceases to apply in relation to a limited liability partnership—
(a) on the appointment of a liquidator or (if earlier) the making of a winding up order by the court, or
(b) on the occurrence of any event under the law of a territory outside the United Kingdom corresponding to an event specified in paragraph (a).
1273A Limited liability partnerships: salaried members
(1) Subsection (2) applies at any time when section 863A(2) of ITTOIA 2005 (limited liability partnerships: salaried members) applies in the case of an individual (“M”) who is a member of a limited liability partnership in relation to which section 1273(1) applies.
(2) In relation to the charge to corporation tax on income, for the purposes of the Corporation Tax Acts—
(a) M is to be treated as being employed by the limited liability partnership under a contract of service instead of being a member of the partnership, and
(b) accordingly, M's rights and duties as a member of the limited liability partnership are to be treated as rights and duties under that contract of service.
(1) This Part applies if—
(a) a company is liable for corporation tax on income arising in a territory outside the United Kingdom, and
(b) the income is unremittable.
(2) For the purposes of this Part, income is unremittable if conditions A and B are met.
(3) Condition A is that the income cannot be transferred to the United Kingdom by the company which is liable for corporation tax in respect of the income because of—
(a) the laws of the territory where the income arises,
(b) executive action of its government, or
(c) the impossibility of obtaining there currency that could be transferred to the United Kingdom.
(4) Condition B is that the company which is liable for corporation tax in respect of the income has not realised it outside that territory for an amount in sterling or in another currency which the company is not prevented from transferring to the United Kingdom.
(1) If a company liable for corporation tax on unremittable income makes a claim for relief under this section in respect of that income, it is not taken into account for corporation tax purposes.
(2) Subsection (1) is subject to section 1276.
(3) No claim under this section may be made in respect of any income so far as an ECGD payment has been made in relation to it.
(4) In subsection (3) “ECGD payment” means a payment made by the Export Credits Guarantee Department under an agreement entered into as a result of arrangements made under—
(a) section 2 of the Export and Investment Guarantees Act 1991 (c. 67) (insurance in connection with overseas investment), or
(b) section 11 of the Export Guarantees and Overseas Investment Act 1978 (c. 18).
(5) A claim under this section must be made before the expiry of 2 years after the end of the accounting period in which the income arises.
(1) This section applies if—
(a) a claim under section 1275 has been made in relation to any income, and
(b) either—
(i) the income ceases to be unremittable, or
(ii) an ECGD payment is made in relation to it.
(2) In this section “ECGD payment” has the meaning given by section 1275(4).
(3) If income ceases to be unremittable, the income is treated as arising on the date on which it ceases to be unremittable.
(4) If an ECGD payment is made in relation to income, the income is treated, to the extent of the payment, as arising on the date on which the ECGD payment is made.
(5) The income treated as arising under subsection (3) or (4), and any tax payable in respect of it under the law of the territory where it arises, are taken into account for corporation tax purposes at their value at the date on which the income is treated as arising.
(6) Subsections (3) to (5) do not apply so far as the income has already been treated as arising as a result of this section.
1277 Income charged on withdrawal of relief after source ceases
(1) This section applies if—
(a) income is treated as arising as a result of section 1276, and
(b) at the time it is so treated the company which would have become liable for corporation tax as a result of that section—
(i) has permanently ceased to carry on the trade or property business from which the income arises, or
(ii) in the case of income from another source, has ceased to possess that source.
(2) In the case of income from a trade—
(a) the income is treated as a post-cessation receipt for the purposes of Chapter 15 of Part 3 (trading income: post-cessation receipts), but
(b) in the application of that Chapter to that income, section 189 (extent of charge to tax) is omitted.
(3) In the case of income from a property business—
(a) the income is treated as a post-cessation receipt from a UK property business for the purposes of Chapter 9 of Part 4 (property income: post-cessation receipts), but
(b) in the application of that Chapter to that income, section 281 (extent of charge to tax) is omitted.
(4) In the case of income from another source, the income is taxed as if the company continued to possess that source.
(1) If no claim is made under section 1275 in relation to unremittable income arising in a territory outside the United Kingdom, the amount of the income to be taken into account for corporation tax purposes is determined as follows.
(2) If the currency in which the income is denominated has a generally recognised market value in the United Kingdom, the amount is determined by reference to that value.
(3) In any other case, the amount is determined according to the official rate of exchange of the territory where the income arises.
1279 Exemption of profits from securities free of tax to residents abroad (“FOTRA securities”)
(1) No liability to corporation tax arises in respect of profits from a FOTRA security or a loan relationship represented by such a security if conditions A and B are met.
(2) Subsection (1) is subject to subsection (5).
(3) Condition A is that the profits are stated in the exemption condition to be exempt from corporation tax.
(4) Condition B is that any requirements for obtaining the exemption imposed by the security's conditions of issue are met.
(5) This section does not affect the need to claim repayment of tax within the time limit applicable for a claim.
(6) Section 1280 applies for the interpretation of this section.
(1) In this section and section 1279 “FOTRA security” means—
(a) a security issued with a condition about exemption from taxation authorised by section 22 of F(No.2)A 1931,
(b) a gilt-edged security which was issued before 6th April 1998 and without any such condition (other than 3½% War Loan 1952 Or After), or
(c) 3½% War Loan 1952 Or After.
(2) In section 1279 “the exemption condition” has the meaning given by subsections (3) to (5), according to the kind of FOTRA security involved.
(3) In relation to a security within subsection (1)(a), it means the condition authorised by section 22 of F(No.2)A 1931.
(4) In relation to a security within subsection (1)(b), it means a condition with which 7.25% Treasury Stock 2007 was first issued, being a condition treated by section 161(1) of FA 1998 (non-FOTRA securities)—
(a) as a condition with which the security within subsection (1)(b) was issued, and
(b) as a condition authorised in relation to its issue by section 22 of F(No.2)A 1931.
(5) In relation to 3½% War Loan 1952 Or After, it means a condition of its issue authorised by section 47 of F(No.2)A 1915.
(6) In this section “gilt-edged security” means a security which—
(a) is a gilt-edged security for the purposes of TCGA 1992 (see Schedule 9 to that Act), or
(b) will be such a security on the making of an order under paragraph 1 of Schedule 9 to that Act if the making of the order is anticipated in the prospectus under which the security is issued.
(1) No liability to corporation tax arises in respect of income from authorised savings certificates.
(2) A savings certificate is authorised so far as its acquisition was not prohibited by regulations made by the Treasury limiting a person's holding.
(3) In this section “savings certificates” means—
(a) savings certificates issued under—
(i) section 12 of the National Loans Act 1968 (c. 13) (power of Treasury to borrow),
(ii) section 7 of the National Debt Act 1958 (c. 6) (power of Treasury to issue national savings certificates), or
(iii) section 59 of FA 1920 (power to borrow on national savings certificates),
(b) war savings certificates, as defined in section 9(3) of the National Debt Act 1972 (c. 65), or
(c) savings certificates issued under any enactment forming part of the law of Northern Ireland and corresponding to section 12 of the National Loans Act 1968.
(4) But subsection (3)(c) does not include Ulster Savings Certificates (for which there are special rules in section 1282).
(1) No liability to corporation tax arises in respect of income from authorised Ulster Savings Certificates if condition A or B is met.
(2) Condition A is that —
(a) the holder purchased them, and
(b) at the time of the purchase the holder was resident in Northern Ireland.
(3) Condition B is that the holder is so resident when they are repaid.
(4) An Ulster Savings Certificate is authorised so far as its acquisition was not prohibited by regulations made by the Department of Finance and Personnel limiting a person's holding.
(5) The exemption under this section requires a claim.
(6) In this Part “Ulster Savings Certificates” means savings certificates issued or treated as issued under section 15 of the Exchequer and Financial Provisions Act (Northern Ireland) 1950 (c. 3 (N.I.)).
(1) No liability to corporation tax arises in respect of a payment if it is made—
(a) under an enactment relating to the giving of financial assistance for the provision, maintenance or improvement of housing accommodation or other residential accommodation, and
(b) by way of grant or other contribution towards expenses.
(2) It does not matter whether—
(a) the payment is made to the person who incurs the expenses, or
(b) the expenses have been, or are to be, incurred.
(3) Subsection (1) does not apply so far as the payment is made towards an expense which is deductible in calculating income for any corporation or income tax purpose.
No liability to corporation tax arises in respect of anything received by way of incentive under any regulations made in accordance with Schedule 38 to FA 2000 (regulations for providing incentives for electronic communications).