UK Act of Parliament
2010
United Kingdom
Taxation (International and Other Provisions) Act 2010
At a glance
Enforced by
What's here
46 compliance obligations, 1 practical guide
Penalty landscape
2 of 46 obligations carry an unlimited fine. 1 carries different penalties and 43 have no criminal penalty — flagged in the list below.
Who this Act binds
Business-side actors with duties under this Act, ranked by how often they appear.
- Trader 23
- Any Person 15
- Director or Officer 2
- Licence Holder 1
Plus 5 non-business duties on Crown ministers, regulators, local authorities or tribunals — shown collapsed under each section below.
Relevant guidance
Practical guides for businesses affected by this Act, ordered by how closely they engage with it.
Direct — cites this Act
1 guidesOther Acts binding the same actors
For each actor bound by this Act, the other UK Acts that bind them most often. Useful for understanding the full compliance landscape facing each role.
Traders also bound by 826 other Acts (top 5 shown)
- Value Added Tax Regulations 1995 1995 413 duties
- Companies Act 2006 2006 243 duties
- The Large and Medium-sized Companies and Groups (Accounts and Reports) Regulations 2008 2008 114 duties
- Insolvency (England and Wales) Rules 2016 2016 62 duties
- Building Societies Act 1986 1986 56 duties
Any Person also bound by 2338 other Acts (top 5 shown)
- Human Medicines Regulations 2012 2012 169 duties
- Merchant Shipping Act 1995 1995 144 duties
- Insolvency (England and Wales) Rules 2016 2016 101 duties
- Road Traffic Act 1988 1988 95 duties
- Air Navigation Order 2016 2016 95 duties
Directors and Officers also bound by 425 other Acts (top 5 shown)
- Insolvency (England and Wales) Rules 2016 2016 161 duties
- Companies Act 2006 2006 108 duties
- Insolvency Act 1986 1986 72 duties
- The Large and Medium-sized Companies and Groups (Accounts and Reports) Regulations 2008 2008 55 duties
- The Housing Administration (England and Wales) Rules 2018 2018 26 duties
Licence Holders also bound by 221 other Acts (top 5 shown)
- Petroleum (Current Model Clauses) Order 1999 1999 317 duties
- The Petroleum Licensing (Exploration and Production) (Seaward and Landward Areas) Regulations 2004 2004 123 duties
- Human Medicines Regulations 2012 2012 76 duties
- Space Industry Regulations 2021 2021 68 duties
- The Petroleum (Production) (Landward Areas) Regulations 1991 1991 65 duties
What this Act requires
Sections that create concrete duties on businesses or carry penalties. Procedural and definitional sections are folded into the “Browse other sections” expander at the bottom of each group. Click any section title to read the source text on legislation.gov.uk.
Part 1 — Overview
Browse 1 other section in this Part — procedural / definitional / commencement
Overview of Act
Part 2 — Double taxation relief
Amount of limit
- Calculate and limit Foreign Tax Credit against income tax Any Person
- Calculate foreign tax credit within the statutory limit Any Person
Amount of limit
- Calculate and claim capital gains tax credit within the allowed limit Any Person
- Calculate the limit for foreign tax credit against Capital Gains Tax Any Person
Credit against tax on trade income
- Calculate and claim corporation tax credit on trade income correctly Director or Officer
- Limit foreign tax credits against your trade income Trader
Limit on credit in cases involving qualifying loan relationships of CFCs
- Calculate and limit loan‑relationship tax credit for UK companies with CFC links Trader
- Limit foreign tax credit claims for certain CFC loan relationships Trader
Applying section 42(2) to non-trading credits from loan relationships etc
- Calculate foreign tax credit limits for non‑trading credits Director or Officer
- Limit foreign tax credit claims on non-trading loan relationship income Trader
Non-trading debits on loan relationships
- Allocate non-trading debits correctly for double taxation relief Trader
Duty to give notice that adjustment has rendered credit excessive
- Notify HMRC if foreign tax credit is reduced or becomes excessive Any Person
Companies with more than one category of business: restriction of credit
- Restrict foreign tax credit across insurance business categories Trader
Interpreting sections 99 to 101 for life assurance or gross roll-up business
Amended 1 timeInterpreting sections 99 to 101 ...
Amended 1 timeInterpreting sections 100 and 101: amounts referable to category of business
Amended 1 timeDeduction from income for foreign tax (instead of credit against UK tax)
Amended 8 timesDuty to give notice that adjustment has rendered reduction too large
- Notify HMRC if a foreign tax adjustment makes your UK tax relief too high Any Person
- Notify HMRC if a foreign tax reduction becomes too large Any Person
Introduction to section 117
Amended 11 timesTax treated as chargeable in respect of transfer of loan relationship, derivative contract or intangible fixed assets
Amended 2 timesIntroduction to section 119
Amended 13 timesTax treated as chargeable in respect of transfer of loan relationship, derivative contract or intangible fixed assets
Amended 2 timesIntroduction to section 121
Amended 2 timesTax treated as chargeable in respect of relevant transactions
Amended 1 timeTax treated as chargeable in respect of gains on transfer of non-UK business
Amended 1 timeInterpretation of sections 116 to 122
Amended 2 timesGiving effect to solutions to cases and mutual agreements resolving cases
Amended 1 timeSpecial relationship rule for royalties: matters to be shown by taxpayer
- Show HMRC that royalty payments are at a fair market rate Any Person
- Show no special relationship or calculate royalty rates for HMRC Trader
Browse 120 other sections in this Part — procedural / definitional / commencement
Giving effect to arrangements made in relation to other territories
Arrangements may include retrospective or supplementary provision
Meaning of “double taxation” in sections 2 and 3
Orders under section 2: contents and procedure
The effect given by section 2 to double taxation arrangements
General regulations
Interpretation: “ unilateral relief arrangements ” means rules 1 to 9, etc
Rule 1: the unilateral entitlement to credit for non-UK tax
Rule 2: accrued income profits
Rule 3: interaction between double taxation arrangements and rules 1 and 2
Rule 4: cases in which, and calculation of, credit allowed for tax on dividends
Rule 5: credit for tax charged directly on dividend
Rule 6: credit for underlying tax on dividend paid to 10% associate of payer
Rule 7: credit for underlying tax on dividend paid to sub-10% associate
Rule 8: credit for underlying tax on dividend paid by exchanged associate
Rule 9: credit in relation to dividends for spared tax
Entitlement to credit for foreign tax reduces UK tax by amount of the credit
Time limits for claims for relief under section 18(2)
Foreign tax includes tax spared because of international development relief
Meaning of “the arrangements”, “the non-UK territory”, “foreign tax” etc
Credit for foreign tax on overlap profit if credit for that tax already allowed
Time limits for claims for relief under section 22(2)
Claw-back of relief under section 22(2)
Credit not allowed if relief allowed against overseas tax
Credit not allowed under arrangements unless taxpayer is UK resident
Credit not allowed if person elects against credit
Unilateral relief for Isle of Man or Channel Islands tax
Unilateral relief for tax on income from employment or office
Unilateral relief for non-UK tax on non-resident's UK branch or agency etc
Calculation of income or gain where remittance basis does not apply
Calculation of amount received where UK tax charged on remittance basis
Limit on credit: minimisation of the foreign tax
Reduction in credit: payment by reference to foreign tax
Disallowed credit: use as a deduction
Credit against tax on trade income: further rules
Credit against tax on royalties: further rules
Credit reduced by reference to accrued income losses
Amount of limit
Amount of limit
Profits attributable to permanent establishments for purposes of section 42(2)
Credit against tax on trade income: anti-avoidance rules
Applying section 44(2): asset in hedging relationship with derivative contract
Applying section 44(2): royalty income
Applying section 44(2): “portfolio” of transactions, arrangements or assets
Restricting section 44(3) if company is a bank or connected with a bank
Tax for period on loan relationships
Tax for period on intangible fixed assets
General deductions
Earlier years' non-trading deficits on loan relationships
Current year's non-trading deficits on loan relationships
Non-trading debits on intangible fixed assets
Credit in respect of dividend: taking account of underlying tax
Calculation if dividend paid by non-resident company to resident company
Meaning of “relevant profits” in section 58
Underlying tax to be left out of account on claim to that effect
Calculation if section 58 does not apply
Meaning of “relevant profits” in section 61
Non-UK company dividend paid to 10% investor: relief for UK and other tax
Meaning of “dividend-paying chain” of companies
Relief for underlying tax paid by company lower in dividend-paying chain
Limitations on section 65(4)
Restriction of relief if underlying tax at rate higher than rate of corporation tax
Meaning of “avoidance scheme” in section 67
Dividends paid out of transferred profits
Underlying tax reflecting interest on loans
Foreign taxation of group as single entity
Circumstances in which section 71B applies
Reduction of foreign tax paid on profits of overseas PE
Application of section 73(1)
Carry-forward and carry-back of unrelieved foreign tax
Rules for carrying back unrelieved foreign tax
Two or more establishments treated as a single establishment
Former and subsequent establishments regarded as distinct establishments
Claims for relief under section 73(1)
Meaning of “overseas permanent establishment”
Time limits for action if tax adjustment makes credit excessive or insufficient
Countering effect of avoidance arrangements
Conditions for the purposes of section 81(1)
Schemes and arrangements referred to in section 82(4)
Section 83(2) and (4): schemes enabling attribution of foreign tax
Section 83(2) and (4): schemes about effect of paying foreign tax
Section 83(2) and (4): schemes involving deemed foreign tax
Section 83(2) and (4): schemes about claims or elections etc
Section 83(2) and (4): schemes that would reduce a person's tax liability
Section 83(2) and (4): schemes involving tax-deductible payments
Contents of counteraction notice
Consequences of counteraction notices
Counteraction notices given before tax return made
Counteraction notices given after tax return made
Amendment, closure notices and discovery assessments in section 92 cases
Information made available for the purposes of section 92(4)
Interpretation of sections 89 to 94
Companies with overseas branches: restriction of credit
Commercial allocation of relevant income to different categories of long-term business
Attribution for section 97 purposes if category is gross roll-up business
Allocation of expenses etc in calculations under section 35 of CTA 2009
First limitation for purposes of section 99(2)
Second limitation for purposes of section 99(2)
Meaning of “chargeable gain”
Chapters 1 and 2 apply to capital gains tax separately from other taxes
Disregard of foreign tax referable to derivative contract
Disregard of foreign tax attributable to interest under a loan relationship
Repo cases in which no disregard under section 108
Stock-lending cases in which no disregard under section 108
When payment to beneficiary treated as arising from foreign source
Deduction from capital gain for foreign tax (instead of credit against UK tax)
Time limits for action if tax adjustment makes reduction too large or too small
Effect of, and deadline for, presenting a case
Meaning of “the Arbitration Convention”
Giving effect to agreements, decisions and opinions under the Convention
Disclosure under the Convention
Power by regulations to give effect to international obligations etc
Giving effect to requirements under section 128A regulations
Disclosure under international obligations etc
Disclosure where relief given overseas for tax paid in the United Kingdom
Interpreting provision about UK taxation of profits of foreign enterprises
Interpreting provision about UK taxation of pensions etc
Interpreting provision about interest influenced by special relationship
Interpreting provision about royalties influenced by special relationship
Correcting assessments where relief is available
Part 3 — Double taxation relief for special withholding tax
Browse 10 other sections in this Part — procedural / definitional / commencement
Relief under this Part: introductory
Interpretation of Part
Income tax credit etc for special withholding tax
Amount and application of the deemed tax under section 137
Capital gains tax credit etc for special withholding tax
Provisions about the deemed tax under section 139
Credit under Chapter 2 of Part 2 to be allowed first
Conditions for purposes of section 143
Issue of certificate
Refusal to issue certificate and appeal against refusal
Part 4 — Transfer pricing
Tax calculations to be based on arm's length, not actual, provision
Amended 6 timesThe “participation condition”
Amended 10 timesParticipation condition treated as met: transfer pricing notice
Amended 10 times“Arm's length provision”
Amended 2 timesArm's length provision where actual provision relates to securities
Amended 1 timeArm's length provision where security issued and guarantee given
Amended 1 timeCertain guarantees not capable of being arm’s length
Amended 1 timeElection for deemed guarantee
Amended 1 timeInterpretation of sections 152 and 153
Amended 7 times“ Potential advantage ” in relation to United Kingdom taxation
Amended 1 time“Losses” and “profits”
Amended 4 timesDirect participation
Amended 13 timesIndirect participation: defined by sections 159 to 161
Amended 8 timesIndirect participation: potential direct participant
Amended 11 timesIndirect participation: one of several major participants
Amended 10 timesIndirect participation: involvement in financing arrangements
Amended 2 timesIndirect participation: sections 148 , 175 and 219(2): further financing cases
Amended 2 timesAgreements for common management
Amended 2 timesArrangements to avoid participation condition
Amended 2 timesMeaning of “connected” in section 159
Amended 1 timePart to be interpreted in accordance with OECD principles
Amended 9 timesUK to UK Exemption
Amended 9 timesExemption for small and medium-sized enterprises
Amended 2 timesAppeals against transfer pricing notices
Amended 5 timesTax returns where transfer pricing notice given
Amended 3 timesClaim by the affected person who is not potentially advantaged
Amended 6 timesClaims under section 174 where disadvantaged person within charge to income tax
Amended 6 timesApplication of section 174 where guarantee disallowed
Amended 1 timeClaims under section 174: advantaged person must have made return
Amended 1 time- Ensure tax returns reflect arm's length calculations before making a claim Any Person
- Make a tax return calculation on an arm’s‑length basis before claiming relief Any Person
Compensating payment if advantaged person is controlled foreign company
Amended 6 timesSection 182 applies to claims where actual provision relates to a security
Amended 3 timesWhen sections 192 to 194 apply
Amended 9 timesAttribution to guarantor company of things done by borrower
Amended 8 timesProvision for cases within Part 6A
Amended 8 timesInteraction between claims under sections 174 and 192(1)
Amended 7 timesClaims under section 192(1): general provisions
Amended 3 timesQualifying conditions for purposes of section 198
Amended 8 timesBalancing payments by guarantor to issuer: no charge to, or relief from, tax
Amended 7 timesPre-conditions for making election under section 200
Amended 3 timesElection to pay tax rather than make balancing payments
Amended 3 timesPre-conditions for making election under section 202
Amended 2 timesElection, in guarantee case, to pay tax rather than make balancing payments
Amended 3 timesElections under section 200 or 202
Amended 5 timesThe requirement for the Commissioners' sanction
Amended 1 timeCapital allowances
Amended 1 timeBrowse 39 other sections in this Part — procedural / definitional / commencement
Application of this Part
“Actual provision” and “affected persons”
“Transaction” and “series of transactions”
Exemption for dormant companies
Small and medium-sized enterprises: exceptions from exemption
Small enterprises: exception from exemption: transfer pricing notice
Medium-sized enterprises: exception from exemption: transfer pricing notice
Giving of transfer pricing notices
Meaning of “small enterprise” and “medium-sized enterprise”
Meaning of “qualifying territory” and “non-qualifying territory”
Exchange gains and losses arising as a result of qualifying loan relationships and derivative contracts
Time for making, or amending, claim under section 174
Meaning of “return” in sections 176 and 177
Application of section 174(2)(a) in relation to transfers of trading stock etc
Making of section 182 claims
Giving effect to section 182 claims
Amending a section 182 claim if it is followed by relevant notice
Notice to potential claimants
Extending claim period if notice under section 185 not given or given late
Tax treatment if actual interest exceeds arm's length interest
Excess interest treated as a ... distribution
Double taxation relief by way of credit for foreign tax
Double taxation relief by way of deduction for foreign tax
Meaning of “relevant notice”
Qualifying conditions for purposes of section 196
Balancing payments between affected persons: no charge to, or relief from, tax
Meaning of “capital market condition” in sections 199 and 201
Provision made or imposed between ring-fence trade and other activities
Meaning of “oil-related ring-fence trade” in sections 205 and 218
Modification of basic rule where allowances restricted for certain expenditure
Application of Part to unit trusts
The determinations which require the Commissioners' sanction
Determinations exempt from requirement for Commissioners' sanction
Restriction of right to appeal against Commissioners' approval
Appeals
Chargeable gains
Manner of making adjustments to give effect to Part
Meaning of “the relevant activities”
Meaning of “control” and “firm”
Part 4A — Assessment of unassessed transfer pricing profits
Browse 19 other sections in this Part — procedural / definitional / commencement
Introduction
Unassessed transfer pricing profits
Conditions for being assessed under this Part at the UTPP rate
Effective tax mismatch outcome
Tax design condition
Preliminary notices
Representations by the company
Assessment
Amendment of company tax return by company
Amendment of assessment by HMRC
No postponement except before assessment is finalised for tax on same profits
Closure notices: rules relating to period for amendments
Appeal against assessment
Review of assessment
Settling of appeal by agreement
No repayment
Exclusion of reliefs, deductions and set-offs
Assessment otherwise than at UTPP rate: no deduction for excess losses
Interpretation
Part 5 — Advance pricing agreements
Meaning of “associate” in section 218(2)(e)
Amended 2 timesModifications of agreement for double taxation purposes
Other duties (1) — Crown / regulator
- HMRC must modify Advance Pricing Agreements to match international tax treaties Statutory regulator
Browse 11 other sections in this Part — procedural / definitional / commencement
Meaning of “advance pricing agreement”
Effect of agreement on party to it
Effect of revocation of agreement or breach of its conditions
Effect of agreement on non-parties
Application for agreement
Provision in agreement about years ended or begun before agreement made
Modification and revocation of agreement
Annulment of agreement for misrepresentation
Penalty for misrepresentation in connection with agreement
Party to agreement: duty to provide information
Interpretation of Part: meaning of “Commissioners” and “officer”
Part 6 — Tax arbitrage
Overview
Amended 2 timesSchemes achieving UK tax advantage for a company
Amended 1 timeSchemes involving hybrid entities
Amended 1 timeNotices given after tax return made
Amended 3 timesAmendments, closure notices and discovery assessments where section 256 applies
Amended 2 timesBrowse 24 other sections in this Part — procedural / definitional / commencement
Deduction notices
The deduction scheme conditions
Further provisions about deduction notices
Instruments of alterable character
Shares subject to conversion
Securities subject to conversion
Debt instruments treated as equity
Scheme including issue of shares not conferring qualifying beneficial entitlement
Scheme including transfer of rights under a security
Consequences of deduction notices
The rule against double deduction
Application of the rule against deduction for untaxable payments
Cases where payee's non-liability treated as not a result of scheme
Cases where payee treated as having reduced liability as a result of scheme
The rule against deduction for untaxable payments
Receipt notices
The receipt scheme conditions
Amounts within corporation tax
Further provisions about receipt notices
Exception for dealers
Rule for calculation or recalculation of income etc following receipt notice
Notices given before tax return made
Schemes and series of transactions
Minor definitions
Part 6A — Hybrid and other mismatches
Browse 90 other sections in this Part — procedural / definitional / commencement
Overview of Part
“ Tax ” means certain taxes on income and includes foreign tax etc
References to equivalent provision to this Part under the law of a territory outside the United Kingdom
Meaning of “payment”, “quasi-payment”, “payer”, “payee” etc
The basic rules
Chargeable companies in respect of CFCs and foreign CFCs
Meaning of “hybrid entity”, “investor” and “investor jurisdiction”
Meaning of “permanent establishment”
Overview of Chapter
Circumstances in which the Chapter applies
Hybrid or otherwise impermissible deduction/non-inclusion mismatches and their extent
Interpretation of section 259CB
Counteraction where the payer is within the charge to corporation tax for the payment period
Counteraction where a payee is within the charge to corporation tax
Overview of Chapter
Circumstances in which the Chapter applies
Meaning of “hybrid transfer arrangement”, “underlying instrument” etc
Hybrid transfer deduction/non-inclusion mismatches and their extent
Interpretation of section 259DC
The financial trader exclusion
Counteraction where the payer is within the charge to corporation tax for the payment period
Counteraction where a payee is within the charge to corporation tax
Overview of Chapter
Circumstances in which the Chapter applies
Hybrid payer deduction/non-inclusion mismatches and their extent
Counteraction where the hybrid payer is within the charge to corporation tax for the payment period
Counteraction where a payee is within the charge to corporation tax
Overview of Chapter
Circumstances in which the Chapter applies
Counteraction of the excessive PE deduction
Meaning of excessive PE inclusion income
Overview of Chapter
Circumstances in which the Chapter applies
Hybrid payee deduction/non-inclusion mismatches and their extent
Counteraction where the payer is within the charge to corporation tax for the payment period
Counteraction where the investor is within the charge to corporation tax
Counteraction where a hybrid payee is an LLP
Overview of Chapter
Circumstances in which the Chapter applies
Multinational payee deduction/non-inclusion mismatches and their extent
Counteraction of the multinational payee deduction/non-inclusion mismatch
Overview of Chapter
Circumstances in which the Chapter applies
Counteraction where the investor is within the charge to corporation tax
Counteraction where the hybrid entity is within the charge to corporation tax
Deemed dual inclusion income for the purposes of section 259IC
Section 259ID income for the purposes of section 259IC
Overview of Chapter
Circumstances in which the Chapter applies
Counteraction where mismatch arises because of a dual resident company
Counteraction where mismatch arises because of a relevant multinational and the UK is the parent jurisdiction
Counteraction where mismatch arises because of a relevant multinational and is not counteracted in the parent jurisdiction
Meaning of excessive PE inclusion income
Overview of Chapter
Circumstances in which the Chapter applies
Meaning of “dual territory double deduction”, “excessive PE deduction” and “PE jurisdiction”
Denial of the relevant deduction in relation to the imported mismatch payment
Deductions from dual inclusion income
Limit on reduction under section 259KC
Provision for cases within Part 4
Adjustments where suppositions cease to be reasonable
Deduction from taxable total profits where an amount of ordinary income arises late
Adjustments in light of later treatment for accounting purposes
Countering the effect of avoidance arrangements
Meaning of “transparent fund”
Application of Chapters 3, 4, 5 and 7
Application of Chapter 9
Application of Chapter 11
Meaning of “financial instrument”
Meaning of “relevant investment fund”
Control groups
Related persons
Meaning of “50% investment” and “25% investment”
Meaning of “qualifying institutional investor” etc
Treatment of a person who is a member of a partnership
Priority
Relevant debt relief circumstances: introductory
Release of debts
Release of connected companies debts
Release of connected companies debts during creditor’s insolvency
Corporate rescue: debt released shortly after connection arises
Securitisation companies
Definitions
Overview of Chapter
Circumstances in which Chapter applies
Claims for allocation of DII surplus
The unused part of the DII surplus
The unused part of the DII shortfall
Groups of companies
Meaning of “dual inclusion income” and “counteraction amount”
Part 7 — Tax treatment of financing costs and income
Introduction
Amended 1 timeUK net debt of worldwide group for period of account of worldwide group
Amended 5 timesNet debt of a company
Amended 1 timeWorldwide gross debt of worldwide group for period of account of the group
Amended 1 timeReferences to amounts disclosed in balance sheet of a company
Amended 3 timesDifferent accounting treatment used at company and group levels
Amended 3 timesQualifying financial services groups
Amended 1 timeInsurance activities and insurance-related activities
Amended 1 timeRelevant dealing in financial instruments
Amended 3 timesUK trading income of the worldwide group
Amended 5 timesForeign currency accounting
Amended 3 timesMeaning of “group securitisation company”
Amended 3 timesAppointment of authorised company for relevant period of account
Amended 1 timeStatement of allocated disallowances: requirements
Amended 1 timeStatement of allocated disallowances: dual resident investing companies
Amended 1 timeFailure of reporting body to submit statement of allocated disallowances
Amended 4 timesSection 284: supplementary
Amended 4 timesAppointment of authorised company for relevant period of account
Amended 1 timeStatement of allocated exemptions: requirements
Amended 6 timesStatement of allocated exemptions: effect
Amended 1 timeFailure of reporting body to submit statement of allocated exemptions
Amended 3 timesBalancing payments between group companies: no tax charge or relief
Amended 2 timesApplication of Chapter to financing income amounts determined under section 314A
Amended 2 timesFinancing income amounts of a company
Amended 4 timesSchemes preventing this Part applying to a large group
Amended 4 timesMeaning of “carried-back amount” and “carried-forward amount”
Amended 2 timesThe financing expense amounts of a company
Amended 2 timesThe financing income amounts of a company
Amended 5 timesThe financing income amounts of a chargeable company under Part 9A
Amended 5 timesInterpretation of sections 313 and 314
Amended 1 timeGroup treasury companies
Amended 4 timesShort-term loan relationships
Amended 2 timesCharities
Amended 1 timeEducational and public bodies
Amended 5 timesThe tested expense amount
Amended 2 timesThe tested income amount
Amended 2 timesThe available amount
Amended 8 timesGroups containing securitisation companies
Amended 8 timesChange of accounting standards: investment entities
Amended 8 timesPartnerships: expenses of borrowing
Amended 8 timesPartnerships: other expenses
Amended 8 timesThe worldwide group
Amended 2 timesMeaning of “ultimate parent”
Amended 3 timesMeaning of “UK group company” and “relevant group company”
Amended 4 timesFinancial statements of the worldwide group
Amended 1 timeNon-existent financial statements of the worldwide group
Amended 3 timesFinancial statements: business combinations to which the worldwide group is a party
Amended 3 timesExpressions taking their meaning from international accounting standards
Amended 2 timesOther expressions
Amended 4 timesEffect of Part on parties to capital market arrangements
Amended 4 timesPower to make regulations where accounting standards change
Amended 4 timesRegulations and orders
Amended 4 timesBrowse 63 other sections in this Part — procedural / definitional / commencement
Application of Part
Qualifying activities
Lending activities and activities ancillary to lending activities
Worldwide trading income of the worldwide group
Application of Chapter and meaning of “total disallowed amount”
Meaning of “company to which this Chapter applies”
Meaning of “dual resident investing company”
Meaning of “the reporting body”
Statement of allocated disallowances: submission
Statement of allocated disallowances: submission of revised statement
Statement of allocated disallowances: effect
Company tax returns
Power to make regulations about statement of allocated disallowances
Powers to make regulations in relation to reductions under section 284
Application of Chapter and meaning of “total disallowed amount”
Meaning of “company to which this Chapter applies”
Meaning of “the reporting body”
Statement of allocated exemptions: submission
Statement of allocated exemptions: submission of revised statement
Company tax returns
Power to make regulations about statement of allocated exemptions
Power to make regulations in relation to reductions under section 296
Tax exemption for certain financing income received from EEA companies
Meaning of “relevant associate”
Meaning of “tax-resident” and “EEA territory”
Qualifying EEA tax relief for payment in current or previous period
Qualifying EEA tax relief for payment in future period
References to tax of a territory
Schemes involving manipulation of rules in Chapter 2
Schemes involving manipulation of rules in Chapters 3 and 4
Meaning of “relevant net deduction”
Calculation of amounts
Schemes involving manipulation of rules in Chapter 5
Meaning of “scheme” and “excluded scheme”
Real estate investment trusts
Companies with permanent establishments profits election
Companies engaged in oil extraction activities
Industrial and provident societies
Intra-group short-term finance: financing expense
Intra-group short-term finance: financing income
Stranded deficits in non-trading loan relationships: financing expense
Stranded deficits in non-trading loan relationships: financing income
Stranded management expenses in non-trading loan relationships: financing expense
Stranded management expenses in non-trading loan relationships: financing income
Interpretation of sections 316 to 327
Companies with net financing deduction or net financing income that is small
Mismatches between tax treatment and accounting treatment
Elections disapplying sections 329(5) and 330(5)
Group members with income from oil extraction subject to particular tax treatment in UK
Group members with income from shipping subject to particular tax treatment in UK
Group members with income from property rental subject to particular tax treatment in UK
Meaning of accounting expressions used in this Chapter
Mismatches between tax treatment and accounting treatment
Meaning of “group”
Meaning of “corporate entity”
Meaning of “relevant non-corporate entity”
Treatment of entities stapled to corporate, or relevant non-corporate, entities
Treatment of business combinations
Meaning of “ large ” in relation to a group
Non-compliant financial statements of the worldwide group
References to amounts disclosed in financial statements
Translation of amounts disclosed in financial statements
Meaning of “relevant accounting period”
Part 8 — Offshore funds ETC
Browse 11 other sections in this Part — procedural / definitional / commencement
Power to make regulations about tax treatment of participants
Meaning of “offshore fund”
Meaning of “mutual fund”
Exceptions to definition of “mutual fund”
Meaning of “relevant income-producing asset”
Power to make regulations about exceptions to definition of “mutual fund”
Treatment of umbrella arrangements
Treatment of arrangements comprising more than one class of interest
Meaning of “participant” and “participation”
Meaning of “umbrella arrangements” and “part of umbrella arrangements”
Residence of undertakings for collective investment in transferable securities and alterative investment funds
Part 9 — Amendments to relocate provisions of tax legislation
Browse 8 other sections in this Part — procedural / definitional / commencement
Oil activities
Alternative finance arrangements
Power to amend the alternative finance provisions
Leasing arrangements: finance leases and loans
Sale and lease-back etc
Factoring of income etc
UK representatives of non-UK residents
Miscellaneous relocations
Part 9A — Controlled foreign companies
Elections and designations about residence
Other duties (1) — Crown / regulator
- HMRC must notify chargeable companies of CFC residence designation Statutory regulator
Browse 140 other sections in this Part — procedural / definitional / commencement
Overview of Part
Introduction to the CFC charge
The CFC charge gateway
Charging the CFC charge
Chargeable companies
Companies which are managers of offshore funds etc
Companies which are participants in offshore funds
Companies holding shares as trading assets etc
Companies carrying on BLAGAB
Banking companies
Does Chapter 4 apply?
Does Chapter 5 apply?
Incidental non-trading finance profits: the 5% rule
Incidental non-trading finance profits: the further 5% rule
Does Chapter 6 apply?
Section 371CE: meaning of “group treasury company”
Does Chapter 7 apply?
Does Chapter 8 apply?
Introduction to Chapter
The steps
Exclusion: UK activities a minority of total activities
Exclusion: economic value
Exclusion: independent companies' arrangements
Exclusion: trading profits (the basic rule)
Exclusion: trading profits (business premises condition)
Exclusion: trading profits (income condition)
Exclusion: trading profits (management expenditure condition)
Exclusion: trading profits (IP condition)
Exclusion: trading profits (export of goods condition)
Exclusion: trading profits (anti-avoidance)
The basic rule
UK activities
Capital investment from the UK
Arrangements in lieu of dividends etc to UK resident companies etc
Leases to UK resident companies etc
The basic rule
Qualifying loan relationships
Loans from foreign permanent establishments of UK resident companies
Exclusion: banking business
Exclusion: insurance business
The basic rule
The basic rule
The basic rule
Loans funded out of qualifying resources
What is the “qualifying value” of “relevant pre-acquisition funds or other assets”?
The 75% exemption
The “matched interest profits” exemption
Determining the profits of a qualifying loan relationship
What is a “qualifying loan relationship”?
Exclusions from definition of “qualifying loan relationship”
Power to amend definitions
Claims
Introduction to Chapter
The basic rule
When does an exempt period begin?
How long is an exempt period?
Adjustment of profits passing through the CFC charge gateway
Anti-avoidance
Amendment of company tax returns
Introduction to Chapter
The basic rule
How to determine the territory in which a CFC is resident
What is “the threshold amount”?
Category A income: the basic rule
Category A income: permanent establishments in excluded territories
Category B income
Category C income
Category D income
The IP condition
Introduction to Chapter
The basic rule
Anti-avoidance
Introduction to Chapter
The basic rule
Anti-avoidance
Introduction to Chapter
The basic rule
Reductions to “the local tax amount”
What are “designer rate tax provisions”?
How to determine “the corresponding UK tax”
Application of Chapter
Provision about interpretation
“Relevant interests” of UK resident companies
“Relevant interests” of persons related to UK resident companies
Other “relevant interests”
What is “creditable tax”?
Application of Chapter
Provision about interpretation
The basic rules
Apportionments to be made in proportion to shareholding
Indirect shareholdings
Variable shareholdings
Anti-avoidance
Overview of Chapter
Legal and economic control
Legal and economic control: the 40% rule
Legal and economic control: supplementary provision
Control determined by reference to accounting standards
Power to amend section 371RE etc
Companies in which a UK resident company has more than a 50% investment
Overview of Chapter
What are “assumed taxable total profits” and “assumed total profits”?
What are “the corporation tax assumptions”?
UK residence etc
Close company
Claims and elections
Disapplication of assumption in section 371SF(1)
Elections under section 9A of CTA 2010
Modification of sections 6 and 7 of CTA 2010
Elections for leases to be treated as long funding leases
Intangible fixed assets
Restrictions on certain deductions: deductions allowances
Group relief etc
Corporate interest restriction
Capital allowances
Unremittable overseas income
Tax advantages
Disguised interest: application of Chapter 2A of Part 6 of CTA 2009
Shares accounted for as liabilities: application of section 521C of CTA 2009
Double taxation relief: countering effect of avoidance arrangements
The basic rule
How to determine the territory in which the CFC is resident
Introduction to Chapter
Application of the Taxes Acts to the CFC charge
Payments in respect of a charge on a banking company: information to be provided
Just and reasonable apportionments
Relief against sum charged
Appeals affecting more than one person
Recovery of sum charged from other UK resident companies
Definitions
Accounting periods
Accounting profits
Adjustments to accounting profits
Cell companies etc
Connected persons etc
Finance profits
Interests in companies
Property business profits
Relevant finance leases
Regulations
Part 10 — Corporate interest restriction
Disallowance of deductions: full interest restriction return submitted
Amended 1 time- Reduce interest deductions by allocated disallowance amount Trader
Disallowance of deductions: no return, or non-compliant return, submitted
Amended 1 timeDisallowed tax-interest expense amounts carried forward
Amended 2 timesThe tax-interest expense amounts of a company
Amended 1 timeRelevant derivative contract debits
Amended 2 timesRelevant derivative contract credits
Amended 2 timesAmount of interest allowance for a period that is “available” in a later period
Amended 1 timeAmounts not brought into account in determining a company's tax-EBITDA
Amended 5 timesNet group-interest expense
Amended 1 time“Relevant expense amount” and “relevant income amount”
Amended 8 timesSection 411: interpretation
Amended 8 timesAdjusted net group-interest expense
Amended 15 timesQualifying net group-interest expense
Amended 3 timesSection 414: interpretation
Amended 4 timesGroup-EBITDA
Amended 2 timesCapitalised interest brought into account for tax purposes in accordance with GAAP
Amended 7 timesChanges in accounting policy
Amended 4 timesGroup interest and group-EBITDA
Amended 1 timeMeaning of “non-consolidated associate”
Amended 4 timesMeaning of “qualifying infrastructure company”
Amended 5 timesElections under section 433
Amended 2 timesGroup elections modifying the operation of sections 433 and 434
Amended 4 timesMeaning of “qualifying infrastructure activity”
Amended 4 timesExemption for interest payable to third parties etc
Amended 1 timeApplication of section 438: certain creditors treated as qualifying infrastructure companies
Amended 1 timeExemption in respect of certain pre-13 May 2016 loan relationships
Amended 1 timeInterest capacity for group with qualifying infrastructure company etc
Amended 1 timeJoint venture companies
Amended 1 timePartnerships and other transparent entities
Amended 1 timeReal Estate Investment Trusts
Amended 6 timesElections under section 456: deemed debits and credits
- Record deemed debits and credits for notional interest amounts Trader
Attribution of rights and interests
Amended 1 timeMeaning of “non-consolidated subsidiary” and “consolidated subsidiary”
Amended 4 timesOther interpretation
Amended 4 timesBrowse 99 other sections in this Part — procedural / definitional / commencement
Overview
Meaning of “subject to interest restrictions”, “the total disallowed amount” etc
Interest restriction returns
Disallowance of deductions: identification of the tax-interest amounts to be left out of account
Reactivation of interest
Reactivation of deductions: identification of the tax-interest amounts to be brought into account
Set-off of disallowances and reactivations in the same accounting period
Relevant loan relationship debits
The tax-interest income amounts of a company
Relevant loan relationship credits
Double taxation relief
The “net tax-interest expense” or “net tax-interest income” of a company
The worldwide group's aggregate net tax-interest expense and income
Meaning of “impairment loss”
Amounts capitalised in carrying value of intangible fixed assets
The interest capacity of a worldwide group for a period of account
When interest allowance is “used”
Amount of interest allowance for a period of account that is “unexpired” in later period
Carry forward of interest allowance: new holding company
The interest allowance of a worldwide group for a period of account
Basic interest allowance calculated using fixed ratio method
Basic interest allowance calculated using group ratio method
The group ratio percentage
The debt cap
Carry forward of excess debt cap: new holding company
Effect of group ratio (blended) election on group ratio percentage
Effect of group ratio (blended) election on group ratio debt cap
Calculations under sections 401 and 402: investor worldwide groups
Meaning of “investor”, “related party investor” and investor's “share”
The aggregate tax-EBITDA of a worldwide group
The tax-EBITDA of a company
Excluded relevant intangibles debits and excluded relevant intangibles credits
Double taxation relief
The capital (expenditure) adjustment
The capital (fair value movement) adjustment
The capital (disposals) adjustment
Derivative contracts subject to fair value accounting
Derivative contracts subject to fair value accounting: interpretation
Group-EBITDA (chargeable gains) election
Employers' pension contributions
Unpaid employees’ remuneration
Employee share acquisitions
Section 427: associated worldwide groups
Interest allowance (consolidated partnerships) election
Interpretation of Chapter
Overview of Chapter
Section 436: supplementary
Loans etc made by qualifying infrastructure companies to be ignored
Tax-EBITDA of qualifying infrastructure company to be nil
Amounts of qualifying infrastructure company left out of account for other purposes
Joint venture groups
Joint ventures: supplementary
Decommissioning
Minor definitions for purposes of this Chapter
Banking companies
Oil and gas
Insurance entities
Members of Lloyd's
Investments held by investment managers
Shipping companies subject to tonnage tax
Creditor relationships of companies determined on basis of fair value accounting
Co-operative and community benefit societies etc
Charities
Long funding operating leases and finance leases
Counteracting effect of avoidance arrangements
Expressions relating to “related parties”: introduction
Whether a person is generally a “related party” of another
Meaning of “25% investment”
Certain loan relationships etc to be treated as made between related parties
Holdings of debt and equity in same proportions
Debts with same rights where unrelated parties hold more than 50%
Debt restructuring
Ordinary independent financing arrangements by banks and others
Loans made by relevant public bodies
Finance leases granted before 20 March 2017
Meaning of “a worldwide group”, “ultimate parent” etc
Interpretation of section 473: “relevant entity”
Continuity of identity of a worldwide group through time
Treatment of stapled entities
Treatment of business combinations
“Financial statements” of a worldwide group
“Period of account” of worldwide group
Actual financial statements not drawn up on acceptable principles
Actual financial statements drawn up on acceptable principles but consolidating wrong subsidiaries
Actual financial statements covering more than one worldwide group
No actual financial statements: ultimate parent draws up financial statements
No actual financial statements: other cases
Election altering period of account deemed under section 485
Actual financial statements ignored if for too long a period or too late
Meaning of “IAS financial statements”
References to amounts recognised in financial statements
Meaning of “relevant accounting period”
Meaning of “relevant public body”
Meaning of “ UK group company”
Embedded derivatives
Financial statements: different treatment by group or members
Parties to capital market arrangements
Change in accounting standards
Regulations
Part 11 — General provisions
Orders and regulations
Amended 1 timeAbbreviated references to Acts
Amended 1 timeMinor and consequential amendments
Amended 1 timeTransitional provisions and savings
Amended 1 timeRepeals and revocations
Amended 1 timeIndex of defined expressions
Amended 3 timesExtent
Amended 1 timeCommencement
Amended 9 timesShort title
Amended 1 timeSchedules
After section 681CG insert— Chapter 4 Leased assets: capital sums...
- Report and pay tax on capital sums from leased asset interests Any Person
After section 271G insert— Exceptions: criminal offences and penalties etc...
- Criminal offence by independent agent of non-UK resident Any Person
After section 77G insert— Supplementary Calculations under sections 77C(3) and...
- Provide licence-related information to HMRC on request Licence Holder
After section 682 (assessments, adjustments and claims after the administration...
- Provide estate income statement to beneficiaries upon written request Any Person
After section 106 insert— Evasion Offence of fraudulent evasion of...
Unlimited fine- Fraudulently evade income tax Any Person
Omit section 144 (offence of fraudulent evasion of income tax)....
Unlimited fine- Fraudulently evade income tax Any Person
(1) The statement of allocated interest restrictions required by paragraph...
- Include allocated interest restrictions statement in your full interest restriction return Trader
(1) The statement of allocated interest reactivations required by paragraph...
- Include a statement of allocated interest reactivations in your full interest restriction return Trader
(1) This paragraph applies in relation to a statement under—...
- Notify HMRC if estimated information in interest restriction return is still not final after 36 months Trader
(1) An officer of Revenue and Customs may amend an...
Other duties (1) — Crown / regulator
- HMRC may correct interest restriction returns within 9 months Statutory regulator
(1) A company which is a reporting company in relation...
- Keep and preserve records for interest restriction returns Trader
(1) This paragraph applies where a closure notice is given...
- Comply with steps in HMRC closure notice after an enquiry Trader
(1) If, as a result of a closure notice given...
- Submit interest restriction returns within 3 months of HMRC closure notice Trader
(1) This paragraph applies if— (a) an enquiry has been...
Other duties (1) — Crown / regulator
- HMRC must appoint a reporting company for the new group within 30 days Statutory regulator
(1) This paragraph applies where— (a) an officer of Revenue...
Other duties (1) — Crown / regulator
- HMRC must notify companies of interest restriction determinations Statutory regulator
(1) This paragraph applies where— (a) as a result of...
- Disallow tax-interest expenses equal to HMRC's determined pro-rata share Trader
(1) This paragraph applies where the appointment of a reporting...
- Notify group companies of reporting company appointment Trader
(1) The reporting company in relation to a period of...
- Share interest restriction returns and HMRC notices with UK group companies Trader
The following elections (or their revocation) must be made by...
- Include certain tax elections or revocations in company tax return Trader
(1) A company may amend its company tax return for...
- Amend company tax return within specified deadlines for certain elections and s.376 requirements Trader
(1) A reporting company appointed under paragraph 1 in relation...
- Submit a reporting company tax return to HMRC before the filing date Trader
(1) If— (a) a company has delivered a company tax...
- Amend your company tax return after an interest restriction return Trader
(1) This paragraph applies where— (a) the appointment of a...
- Submit revised interest restriction return when figures become incorrect Trader
Browse 677 other Schedules — structural / supplementary
Miscellaneous relocations
Repeals and revocations
ITTOIA 2005 is amended as follows.
After section 225 insert— Chapter 16A Oil activities Basic definitions...
Alternative finance arrangements
ITA 2007 is amended as follows.
After section 564H insert— Meaning of “alternative finance return” Purchase...
After section 564I insert— Purchase and resale arrangements where return...
After section 564J insert— Diminishing shared ownership arrangements (1) In the case of diminishing shared ownership arrangements, payments...
After section 564K insert— Other arrangements (1) In the case of deposit arrangements, amounts paid or...
After section 564L insert— Treatment of alternative finance return as...
After section 564M insert— Alternative finance return under arrangements for...
After section 564N insert— Relief for some alternative finance return...
After section 564O insert— Tax relief schemes and arrangements Section 809ZG (tax relief schemes and arrangements) applies to alternative...
After section 564P insert— Deduction of income tax at source...
After section 564Q insert— Special rules for investment bond arrangements...
After Part 10 insert— Part 10A Alternative finance arrangements Introduction...
After section 564R insert— Treatment of bond-holder and bond-issuer (1) This section applies for the purposes of the Income...
After section 564S insert— Treatment as securities (1) Investment bond arrangements are securities for the purposes of...
After section 564T insert— Arrangements not unit trust scheme or...
After section 564U insert— Other rules Exclusion of alternative finance...
After section 564V insert— Diminishing shared ownership arrangements not partnerships...
After section 564W insert— Treatment of principal under profit share...
After section 564X insert— Provision not at arm's length: relevant...
TCGA 1992 is amended as follows.
After Chapter 3 of Part 4 insert— Chapter 4 Alternative...
After section 151H insert— Meaning of “financial institution” (1) In this Chapter “financial institution” means—
After section 564A insert— Meaning of “financial institution” (1) In this Part “financial institution” means—
After section 151I insert— Arrangements that are alternative finance arrangements...
After section 151J insert— Diminishing shared ownership arrangements (1) This section applies to arrangements if under them—
After section 151K insert— Deposit arrangements (1) This section applies to arrangements if under them—
After section 151L insert— Profit share agency arrangements (1) This section applies to arrangements if under them—
After section 151M insert— Investment bond arrangements (1) This section applies to arrangements if—
After section 151N insert— Provision not at arm's length: exclusion...
After section 151O insert— Meaning of “alternative finance return” Purchase...
After section 151P insert— Purchase and resale arrangements where return...
After section 151Q insert— Diminishing shared ownership arrangements (1) In the case of diminishing shared ownership arrangements, payments...
After section 151R insert— Other arrangements (1) In the case of deposit arrangements, amounts paid or...
After section 564B insert— Arrangements that are alternative finance arrangements...
After section 151S insert— Special rules for investment bond arrangements...
After section 151T insert— Treatment of bond-holder and bond-issuer (1) This section applies for the purposes of this Act...
After section 151U insert— Treatment as securities (1) Investment bond arrangements are securities for the purposes of...
After section 151V insert— Investment bond arrangements not unit trust...
After section 151W insert— Other rules Exclusion of some alternative...
After section 151X insert— Diminishing shared ownership arrangements not partnerships...
ICTA is amended as follows.
After section 367 insert— Alternative finance arrangements (1) Sections 353 and 365 have effect as if—
ITEPA 2003 is amended as follows.
After section 173 (loans to which Chapter 7 of Part...
After section 564C insert— Diminishing shared ownership arrangements (1) This section applies to arrangements if under them—
ITA 2007 is amended as follows.
At the beginning of Chapter 7 of Part 7 (Community...
After section 372A insert— Purchase and resale arrangements (1) This section applies if, under arrangements to which section...
After section 372B insert— Deposit arrangements (1) This section applies if, under arrangements to which section...
After section 372C insert— Profit share agency arrangements (1) This section applies if, under arrangements to which section...
In section 1005 (meaning of “recognised stock exchange” etc) after...
After section 564D insert— Deposit arrangements (1) This section applies to arrangements if under them—
After section 564E insert— Profit share agency arrangements (1) This section applies to arrangements if under them—
After section 564F insert— Investment bond arrangements (1) This section applies to arrangements if—
After section 564G insert— Provision not at arm's length: exclusion...
ITA 2007 is amended as follows.
After Part 11 insert— Part 11A Leasing arrangements: finance leases...
After section 614AC insert— Chapter 2 Finance leases with return...
After section 614BY insert— Chapter 3 Other finance leases Introduction...
After section 614CD insert— Chapter 4 Supplementary provisions Pre-26 November...
TCGA 1992 is amended as follows.
After section 37 insert— Consideration on disposal of certain leases...
ITA 2007 is amended as follows.
After section 681 insert— Part 12A Sale and lease-back etc...
After section 681AN insert— Chapter 2 New lease of land...
After section 681BM insert— Chapter 3 Leased trading assets Overview...
ITA 2007 is amended as follows.
After section 809AZG insert— Chapter 5B Finance arrangements Type 1...
After section 809BZE insert— Type 2 arrangements Type 2 finance...
After section 809BZI insert— Type 3 arrangements Type 3 finance...
After section 809BZL insert— Exceptions Exceptions: preliminary (1) Sections 809BZN to 809BZP make provision for finance arrangement...
After section 809BZP insert— Supplementary Accounts (1) This section applies for the purposes of this Chapter....
After section 809BZS insert— Chapter 5C Loan or credit transactions...
After section 835B of ITA 2007 (which is inserted by...
After section 835K insert— The independent broker conditions The independent...
After section 835L insert— The independent investment manager conditions The...
After section 835M insert— Investment managers: the 20% rule (1) The requirements of the 20% rule are met if...
After section 835N insert— Meaning of “qualifying period”, “relevant disregarded...
After section 835O insert— Treatment of transactions where 20% rule...
After section 835P insert— Application of 20% rule to collective...
After section 835Q insert— Supplementary Supplementary provision (1) For the purposes of this Chapter a person is...
After section 835R insert— Interpretation of Chapter (1) This section applies for the purposes of this Chapter....
After section 835S insert— Chapter 2C Income tax obligations and...
After section 835T insert— Obligations and liabilities of UK representative...
After section 835C insert— Income tax chargeable on company's income:...
After section 835U insert— Exceptions: notices and information (1) An obligation or liability attaching to a non-UK resident...
After section 835V insert— Exceptions: criminal offences and penalties etc...
After section 835W insert— Indemnities (1) An independent agent of a non-UK resident is entitled...
After section 835X insert— Meaning of “independent agent” (1) In this Chapter “independent agent”, in relation to a...
After section 271 of TCGA 1992 insert— Part 7A UK...
After section 271A insert— Branches and agencies Branch or agency...
After section 271B insert— Trade or profession carried on in...
After section 271C insert— Interpretation of Chapter In this Chapter— “branch or agency” means any factorship, agency,...
After section 271D insert— Chapter 2 Capital gains tax obligations...
After section 271E insert— Obligations and liabilities of UK representative...
After section 835D insert— Branches and agencies Branch or agency...
After section 271F insert— Exceptions: notices and information (1) An obligation or liability attaching to a non-UK resident...
After section 271H insert— Indemnities (1) An independent agent of a non-UK resident is entitled...
After section 271I insert— Meaning of “non-UK resident” and “independent...
After section 835E insert— Trade or profession carried on in...
After section 835F insert— Persons who are not UK representatives...
After section 835G insert— Brokers (1) This section applies if a non-UK resident carries on...
After section 835H insert— Investment managers (1) This section applies if a non-UK resident carries on...
After section 835I insert— Persons acting under alternative finance arrangements...
After section 835J insert— Lloyd's agents (1) This section applies if— (a) a non-UK resident (“X”)...
TMA 1970 is amended as follows.
In section 3(4) (expenditure not allowable under the section) for...
The Serious Crime Act 2007 is amended as follows.
(1) Amend Schedule 1 as follows. (2) In paragraph 8(3)...
TMA 1970 is amended as follows.
After section 18A insert— Savings income: regulations about European and...
(1) Amend the first column of the Table in section...
FA 2003 is amended as follows.
Omit section 199 (savings income: power to make regulations in...
FA 1998 is amended as follows.
(1) Amend Schedule 18 (company tax returns, assessments and related...
F(No.2) A 2005 is amended as follows.
TMA 1970 is amended as follows.
Omit section 61 (continuity for transitional purposes in cases involving...
ITA 2007 is amended as follows.
After section 925 insert— Repos Creditor repos (1) Subsection (2) applies if a company (“the lender”) has...
In section 926 (interpretation of Chapter 9 of Part 15)...
FA 2007 is amended as follows.
In Schedule 13 (sale and repurchase of securities) omit paragraph...
In section 8 (personal return) after subsection (4) insert—
After section 8 insert— Interpretation of section 8(4A) (1) For the purposes of section 8(4A) of this Act,...
After section 15 insert— Non-resident's staff are UK client's employees...
FA 1974 is amended as follows.
Omit section 24 (returns of persons treated as employees).
TMA 1970 is amended as follows.
(1) Amend the first column of the Table in section...
ICTA is amended as follows.
After Part 7 insert— Part 7A Holders of licences under...
Omit section 42 (appeals against determinations under Chapter 4 of...
ITTOIA 2005 is amended as follows.
After section 302 insert— Determinations affecting liability of more than...
CTA 2009 is amended as follows.
In section 242(2) (determination by tribunal) for the words from...
ICTA is amended as follows.
Omit section 84A (costs of establishing share option or profit...
ITTOIA 2005 is amended as follows.
In Chapter 5 of Part 2, after section 94 insert—...
In section 272(2) (profits of property business: application of trading...
After section 77E insert— Exemption certificates Issue, cancellation and effect...
TMA 1970 is amended as follows.
(1) Amend section 48 (application of following provisions of Part...
After section 54 insert— No questioning in appeal of amounts...
ICTA is amended as follows.
Omit section 152 (notification of taxable amount of certain benefits)....
ICTA is amended as follows.
Omit section 6(5) (signpost to Part 8 of the Act)....
Omit section 337A(2) (in calculating a company's income, deductions in...
CTA 2009 is amended as follows.
After section 1301 insert— Restriction of deductions for interest In calculating a company's income from any source for corporation...
ICTA is amended as follows.
Omit section 475 (tax-free Treasury securities: exclusion of interest on...
ITTOIA 2005 is amended as follows.
Before section 155 (before the italic cross-heading) insert— Certain non-UK...
ICTA is amended as follows.
Omit section 700 (adjustments and information).
ITTOIA 2005 is amended as follows.
ICTA is amended as follows.
Omit section 787 (restriction of relief for payments of interest)....
(1) Amend the first column of the Table in section...
ITA 2007 is amended as follows.
In section 2(13) (overview of Part 13) after paragraph (h)...
After section 809ZF (which is inserted by CTA 2010) insert—...
TMA 1970 is amended as follows.
After section 109A insert— Companies ceasing to be UK resident...
FA 1988 is amended as follows.
Omit sections 130 to 132 (company migration).
TMA 1970 is amended as follows.
After section 30A insert— Assessing income tax on trustees and...
FA 1989 is amended as follows.
FA 1973 is amended as follows.
Omit section 151 (assessment of trustees and personal representatives).
ITTOIA 2005 is amended as follows.
In Schedule 2 (transitionals and savings etc) omit paragraph 91...
F(No.2)A 1992 is amended as follows.
Omit section 66 (which introduces Schedule 12).
Omit Schedule 12 (banks etc in compulsory liquidation).
ITTOIA 2005 is amended as follows.
In section 369 (charge to tax on interest) after subsection...
ITA 2007 is amended as follows.
In section 2(14) (overview of Act: Part 14) after paragraph...
Omit section 38 (which introduces and interprets Schedule 15).
In section 3(2) (overview of charges to income tax)—
After section 837 insert— Chapter 3A Banks etc in compulsory...
In Schedule 4 (index of defined expressions) at the appropriate...
FA 1996 is amended as follows.
(1) Amend section 200 (domicile for tax purposes of overseas...
ITA 2007 is amended as follows.
In section 2(14)(b) (overview of Act: reference to Chapter 2...
After section 835A insert— Chapter 2A Domicile Domicile for income...
TMA 1970 is amended as follows.
In Part 5A (payment of tax) after section 59E insert—...
Omit Schedule 15 (territorial extension of charge to tax: supplementary...
In Part 5A after section 59F insert— Managed payment plans...
FA 1998 is amended as follows.
Omit section 36 (arrangements with respect to payment of corporation...
FA 2009 is amended as follows.
Omit section 111 (managed payment plans).
TMA 1970 is amended as follows.
In Part 4, after section 43D (which is inserted by...
FA 1998 is amended as follows.
Omit section 118 (claims for income tax purposes).
ITTOIA 2005 is amended as follows.
The Oil Taxation Act 1975 is amended as follows.
(1) Amend section 878 (other definitions) as follows.
ITA 2007 is amended as follows.
In section 989 (interpretation of Income Tax Acts) in the...
(1) Amend section 1020 (claims and elections) as follows.
TMA 1970 is amended as follows.
FA 2000 is amended as follows.
The Serious Organised Crime and Police Act 2005 is amended...
In section 76(3)(n) (offence under section 144 of FA 2000...
Interest restriction returns
(1) An interest restriction return for a period of account...
(1) This paragraph makes provision for the purposes of this...
(1) This paragraph applies where a company—
(1) A company is liable to a penalty if the...
(1) Liability to a penalty under paragraph 11A does not...
(1) An election to which this paragraph applies must be...
(1) This paragraph applies where the appointment of a reporting...
(1) This paragraph applies where— (a) the appointment of a...
(1) This paragraph applies where the appointment of a reporting...
(1) This paragraph applies where the appointment of a reporting...
(1) This paragraph applies where the appointment of a reporting...
(1) This paragraph applies where the appointment of a reporting...
(1) This paragraph applies where the appointment of a reporting...
(1) This paragraph applies where a company has purported to...
(1) A member of a worldwide group may revoke an...
(1) This paragraph makes provision about the contents of an...
The statement of calculations required by paragraph 20(3)(d) to be...
(1) This paragraph— (a) applies in relation to a worldwide...
(1) This paragraph— (a) applies in relation to a worldwide...
(1) This paragraph applies for the purposes of this Part...
(1) A company is liable to a penalty if the...
(1) Liability to a penalty under paragraph 29 does not...
The Commissioners may by regulations make further provision about an...
(1) A company is liable to a penalty if—
(1) For the purposes of this Part of this Schedule...
(1) A company (“C”) is liable to a penalty if—...
(1) If a company liable to a penalty under paragraph...
(1) If a person becomes liable to a penalty under...
A person may, by notice, appeal against—
(1) Notice of an appeal under paragraph 35 must be...
(1) This paragraph applies if— (a) a company (“P”) liable...
(1) A company which fails to comply with paragraph 38...
(1) This paragraph applies where no interest restriction return in...
(1) An officer of Revenue and Customs may enquire into...
(1) This paragraph applies where an interest restriction return is...
(1) Notice of enquiry may be given later than the...
(1) An enquiry into an interest restriction return extends to...
(1) If it appears to an officer of Revenue and...
(1) If after notice of enquiry has been given into...
(1) This paragraph applies if a reporting company submits a...
(1) An enquiry into an interest restriction return submitted by...
(1) An application may be made at any time to...
(1) This paragraph applies where— (a) an appointment of a...
(1) If a closure notice — (a) is given to...
(1) This paragraph applies if— (a) a closure notice is...
(1) This paragraph applies if— (a) anything is required to...
(1) This paragraph applies where— (a) the appointment of a...
(1) Sub-paragraph (2) applies where— (a) a notice of determination...
(1) If a notice of determination under paragraph 58 is...
(1) This paragraph applies where condition A or B is...
(1) An officer of Revenue and Customs may, by notice,...
(1) An officer of Revenue and Customs may, by notice,...
(1) The general rule is that, if an interest restriction...
(1) A group member may appeal against a notice under...
(1) The following provisions of Schedule 36 to FA 2008...
(1) For the purposes of this Part of this Schedule...
(1) This paragraph applies if a company—
(1) The Commissioners may by regulations— (a) make provision generally...
(1) This paragraph applies if— (a) a company amends, or...
In this Schedule “ company tax return ” has the...
A person is not liable to a penalty under any...
Notice of an appeal under this Schedule must specify the...
(1) This paragraph applies to an amount stated in an...
(1) This paragraph applies if— (a) a period of account...
(1) This paragraph applies where— (a) a reporting company has...
TMA 1970 is amended as follows.
In section 750(3)(b) (disregard of certain double taxation relief) for...
In section 931J(7) for “Part 18 of ICTA” substitute “...
In section 1266(1)(b) (resident partners and double taxation agreements) for...
FA 2009 is amended as follows.
In section 56(1) (tax in respect of MEPs' pay) for...
In Schedule 16 in paragraph 7(2)(a) (purposes for which straddling...
In Schedule 35 in paragraph 2(4)(b) for “section 788 of...
TMA 1970 is amended as follows.
In section 9A(4)(b) (scope of enquiries) for “paragraph 5C of...
(1) Amend the second column of the Table in section...
ICTA is amended as follows.
In section 751(6)(a) (“creditable tax” includes amounts of double taxation...
Omit section 770A (which introduces Schedule 28AA).
Omit Schedule 28AA (transfer pricing).
FA 1998 is amended as follows.
Omit section 110 (determinations requiring the sanction of the Commissioners...
Omit section 111 (duty to give notice to persons who...
FA 1999 is amended as follows.
Omit section 85 (advance pricing agreements).
Omit section 86(1) to (8) and (10) (provisions supplementary to...
Omit section 87 (effect of advance pricing agreements on non-parties)....
(1) Schedule 22 to FA 2000 (tonnage tax) is amended...
In section 755A(4A)(b) (dividend paid by controlled foreign company to...
ITTOIA 2005 is amended as follows.
(1) Amend section 172F (transfer pricing rules to take precedence...
In section 173(2) (trading stock not to be valued if...
CTA 2009 is amended as follows.
(1) Amend section 161 (transfer pricing rules take precedence over...
In section 162(2) (trading stock not to be valued if...
In section 340(7) (Schedule 28AA to ICTA does not apply...
In section 374(3)(a) (meaning of non-qualifying territory) for “paragraph 5E...
(1) Amend section 376(5) (interpretation of section 375) as follows....
In section 377(3)(a) (meaning of non-qualifying territory) for “paragraph 5E...
Omit section 788 (giving effect to double taxation arrangements).
In section 407(6)(a) (meaning of non-qualifying territory) for “paragraph 5E...
(1) Amend section 410(5) (interpretation of section) as follows.
In section 444(3) (section is subject to section 445) for...
(1) Amend section 445 (disapplication of section 444 where Schedule...
(1) Amend section 446 (bringing into account adjustments made under...
(1) Amend section 447 (exchange gains and losses on debtor...
In section 452(1)(a) and (3)(a) (exchange gains and losses where...
In section 455(5) (section does not apply if paragraph 1(2)...
In section 464(3)(a) (which refers to and describes section 445(2))...
In section 484(1) (non-lending relationships treated as loan relationships: meaning...
Omit section 789 (conversion of references to the profits tax...
In section 508(2) (arrangements which are not alternative finance arrangements)—...
In section 625(7) (Schedule 28AA to ICTA does not apply...
(1) Amend section 693 (bringing into account adjustments under Schedule...
(1) Amend section 694 (exchange gains and losses where derivative...
In section 698(5) (section does not apply if paragraph 1(2)...
(1) In the provisions mentioned in sub-paragraph (2) (provisions which...
In section 775(3) (intangible fixed assets: transfers within a group)...
(1) Amend section 846 (intangible fixed assets: transfers not at...
In section 931P(4) (section does not apply if Schedule 28AA...
FA 2009 is amended as follows.
Omit section 790 (unilateral relief).
In Schedule 17 (international movement of capital) in paragraph 12(5)...
F(No.2)A 2005 is amended as follows.
Omit sections 24 to 28 (avoidance involving tax arbitrage).
Omit section 30 (interpretation of Chapter 4 of Part 2)....
Omit section 31 (commencement of Chapter 4 of Part 2)....
Omit Schedule 3 (qualifying schemes).
TMA 1970 is amended as follows.
(1) Amend the first column of the Table in section...
FA 2009 is amended as follows.
Omit section 35 (which introduces Schedule 15).
Omit section 791 (power to make regulations giving effect to...
Omit paragraphs 1 to 94 and 97 to 99 of...
The Inheritance Tax Act 1984 is amended as follows.
In section 174(1)(a) (income tax and unpaid inheritance tax) for...
TCGA 1992 is amended as follows.
In section 108(1)(c) (identification of relevant securities for corporation tax)...
In section 212(1)(b) (annual deemed disposal of unit trusts etc)...
In Schedule 7AD (gains of insurance company from venture capital...
ITTOIA 2005 is amended as follows.
In section 378A(7) (offshore fund distributions) for “section 40A of...
FA 2008 is amended as follows.
Omit sections 792 to 798C (which contain rules about double...
Omit sections 40A to 42A (offshore funds).
CTA 2009 is amended as follows.
In section 489 (meaning of “offshore fund etc”)—
FA 2009 is amended as follows.
Omit paragraph 6 of Schedule 22 (restriction on regulation-making power...
FA 1980 is amended as follows.
In section 107(7) (transmedian fields) for “Chapter V of Part...
FA 1982 is amended as follows.
In section 134(1) (alternative valuation of ethane used for petrochemical...
In Schedule 19 (supplementary provisions relating to advance petroleum revenue...
Omit sections 799 and 801 to 801B (double taxation relief:...
ICTA is amended as follows.
Omit section 493(1) to (6) (valuation of oil disposed of...
Omit section 495 (regional development grants).
Omit section 496 (tariff receipts and tax-exempt tariffing receipts).
Omit section 502(1) and (2) (interpretation of Chapter 5).
FA 1991 is amended as follows.
Omit sections 62 to 65 (abandonment guarantees and abandonment expenditure)....
FA 1999 is amended as follows.
In section 98(7) (qualifying assets) for paragraphs (b) and (c)...
ITTOIA 2005 is amended as follows.
Omit sections 803 to 804E and 804G to 806 (further...
In section 16(3) (oil extraction and related activities) for “section...
In Part 2 of Schedule 4 (index of defined expressions)...
ITA 2007 is amended as follows.
In section 80(3) (ring fence income) for “same meaning as...
FA 1986 is amended as follows.
In section 78(7)(d) (loan capital)— (a) for “which fall within...
In section 79 (loan capital: new provisions)—
In section 99(9A) (interpretation)— (a) for “falling within section 48A...
TCGA 1992 is amended as follows.
In section 99(2) (application of Act to unit trust schemes)...
In section 9A(4)(c) (scope of enquiries) for “section 804ZA of...
(1) Amend section 806A as follows. (2) In subsection (2)—...
In section 117 (meaning of “qualifying corporate bond”) for subsection...
Omit section 151F (treatment of alternative finance arrangements).
In the Table in section 288(8) (interpretation), in the entry...
ITEPA 2003 is amended as follows.
In section 420(1) (meaning of securities etc) for paragraph (h)...
FA 2003 is amended as follows.
In section 71A(8) (alternative property finance: land sold to a...
In section 72(7) (alternative property finance in Scotland: land sold...
In section 72A(8) (alternative property finance in Scotland: land sold...
In section 73(5)(a) (alternative property finance: land sold to a...
(1) Amend section 806B as follows. (2) In subsection (2)(b)...
In section 73C (alternative finance investment bonds) for “falling within...
ITTOIA 2005 is amended as follows.
In Part 2 of Schedule 4 (index of defined expressions)...
FA 2005 is amended as follows.
Omit sections 46 to 47A, 48(1), 48A, 48B(1) to (5)...
In Schedule 2 (alternative finance arrangements: further provisions) omit paragraphs...
FA 2006 is amended as follows.
Omit section 97 (beneficial loans to employees).
Omit section 98 (orders amending Chapter 5 of Part 2...
ITA 2007 is amended as follows.
In section 806C(3) and (4) for “this Part” substitute “...
In section 2 (overview of Act) after subsection (10) insert—...
In section 383(6) (relief for interest payments)—
In section 849(4) (interaction with other Income Tax Acts provisions)...
In Schedule 4 (index of expressions defined in that Act)...
CTA 2009 is amended as follows.
Omit section 521 (power to extend Chapter 6 of Part...
Omit section 1310(5) (orders and regulations).
FA 2009 is amended as follows.
In section 123 (alternative finance investment bonds) for “falling within...
(1) Amend Schedule 61 (alternative finance investment bonds) as follows....
In section 806D(3), (4) and (5) for “this Part” substitute...
The Taxation of Chargeable Gains Act 1992 is amended as...
In section 37 (consideration chargeable to tax on income) at...
(1) FA 1997 is amended as follows.
The Capital Allowances Act 2001 is amended as follows.
In section 60(1)(c) (meaning of “disposal receipt”) for “paragraph 11”...
In section 420(b) (meaning of “disposal receipt”) for “paragraph 11”...
In section 476(1)(b) (disposal value of patent rights) for “paragraph...
The Income Tax Act 2007 is amended as follows.
In section 2 (overview of Act) after subsection (11) insert—...
In Schedule 4 (index of defined expressions) at the appropriate...
In section 806F(1) and (2) for “this Part” substitute “...
ICTA is amended as follows.
Omit section 24 (which has come to apply only for...
Omit sections 779 to 785 (sale and lease-back etc).
TCGA 1992 is amended as follows.
In Schedule 8 (leases) in paragraph 9(2) (gain reduced by...
The Broadcasting Act 1996 is amended as follows.
(1) Amend Schedule 7 (transfer schemes: taxation provisions) as follows....
FA 1999 is amended as follows.
In section 97(6), in the definition of “lease”, for “sections...
The Greater London Authority Act 1999 is amended as follows....
(1) Amend section 806J (interpretation of sections 806A to 806J)...
(1) Amend paragraph 13 of Schedule 33 (taxation provisions: public-private...
The Transport Act 2000 is amended as follows.
In paragraph 15 of Schedule 7 (transfer schemes: tax: leased...
ITTOIA 2005 is amended as follows.
(1) Amend section 49 (car or motor cycle hire: supplementary)...
In section 100(4) (meaning of sale and lease-back arrangement) after...
ITA 2007 is amended as follows.
In section 2 (overview of Act) after subsection (12) insert—...
In section 989 at the appropriate place insert— “hire-purchase agreement”...
After section 998 insert— Meaning of “hire-purchase agreement” (1) This section applies for the purposes of the provisions...
Omit sections 806L and 806M (unrelieved foreign tax).
(1) Amend section 1016(2) (table of provisions to which section...
In Schedule 4 (index of defined expressions) at the appropriate...
CTA 2009 is amended as follows.
In section 97(4) (meaning of sale and lease-back arrangement) after...
ICTA is amended as follows.
Omit sections 774A to 774G (factoring of income receipts etc)....
Omit section 786 (transactions associated with loans or credit).
TCGA 1992 is amended as follows.
(1) Amend section 263E (structured finance arrangements) as follows.
ITTOIA 2005 is amended as follows.
Omit sections 807 and 807A (provision, in connection with relief,...
After section 281 insert— Sums to which sections 277 to...
ITA 2007 is amended as follows.
In section 2(13) (overview of Part 13) omit the “or”...
For section 809AZE (transfers of income streams: exception for transfer...
(1) Amend section 1016(2) (table of provisions to which section...
In Schedule 4 (index of defined expressions) at the appropriate...
FA 1995 is amended as follows.
Omit section 126 (UK representatives of non-residents).
Omit section 127 (persons not treated as UK representatives).
Omit Schedule 23 (obligations etc imposed on UK representatives).
Omit sections 807B to 807G (provisions related to the Mergers...
ITA 2007 is amended as follows.
In section 2(14) (overview of Act)— (a) omit the “and”...
In section 813(2) (meaning of “disregarded income”) for “section 126...
(1) Amend section 817 (independent broker conditions) as follows.
In section 824 (application of 20% rule to collective investment...
(1) Amend section 1014(2) (orders and regulations to which section...
In Schedule 4 (index of defined expressions) at the appropriate...
The Solicitors (Northern Ireland) Order 1976 is amended as follows....
In paragraph 38(3) of Schedule 1A for the words from...
The Administration of Justice Act 1985 is amended as follows....
Omit sections 808A to 809 and 811 (provision, in connection...
In paragraph 36(3) of Schedule 2 for “749,” substitute “...
ICTA is amended as follows.
Omit section 59(3) and (4) (person answerable for tax charged...
The Broadcasting Act 1996 is amended as follows.
(1) Amend paragraph 19 of Schedule 7 (no profit or...
The Greater London Authority Act 1999 is amended as follows....
In paragraph 7 of Schedule 33 (taxation provisions: revenue nature...
ITEPA 2003 is amended as follows.
In section 211(2) (which refers to section 215, which in...
In section 215 (which now refers to section 776(1) of...
(1) Amend section 12B (records to be kept for purposes...
In section 331(1) (Part 5 is to be read with...
FA 2004 is amended as follows.
(1) Amend section 318 (interpretation of Part 7) as follows....
FA 2005 is amended as follows.
Omit section 48B(6) to (8) (alternative finance arrangements: alternative finance...
In Schedule 2 (alternative finance arrangements: further provisions) omit paragraph...
ITA 2007 is amended as follows.
In section 887(4) (industrial and provident society payments) for “section...
CTA 2009 is amended as follows.
Before section 1 insert— Overview of the Corporation Tax Acts...
In section 814(1)(a) for “section 788(1)” substitute “ section 2(1)...
In section 39(2) (profits of mines, quarries and other concerns)...
In section 1269 (interpretation of sections 1267 and 1268) in...
In paragraph 75 of Schedule 2 (transitional provision and savings:...
TMA 1970 is amended as follows.
In section 118(1) after the definition of “the 1992 Act”...
ICTA is amended as follows.
In section 831(3) (interpretation of ICTA) after the definition of...
TCGA 1992 is amended as follows.
(1) Amend section 287 (powers to make orders or regulations...
In section 288(1) (interpretation) after the definition of “the Taxes...
Omit sections 815A to 815B and 816 (provision, in connection...
FA 1998 is amended as follows.
(1) Amend Schedule 18 (company tax returns etc) as follows....
ITEPA 2003 is amended as follows.
In Part 1 of Schedule 1 (abbreviations of Acts etc)...
ITTOIA 2005 is amended as follows.
In Part 1 of Schedule 4 (abbreviations of Acts) after...
ITA 2007 is amended as follows.
In section 1014(2) (orders and regulations under the Income Tax...
In section 1017 (abbreviated references to Acts) for the “and”...
CTA 2009 is amended as follows.
In section 828(4) (orders and regulations not subject to annulment)...
In section 1312 (abbreviated references to Acts) after the definition...
FA 2009 is amended as follows.
In section 126(1) (abbreviated references to Acts) after the entry...
(1) Amend Schedule 19ABA (modification of life assurance provisions of...
(1) Amend Schedule 26 (reliefs against liability for tax in...
Omit Schedule 28AB (prescribed schemes and arrangements for purposes of...
FA 1989 is amended as follows.
In section 115(1) (tax credits for dividends paid to non-residents...
In section 182A(6) (double taxation: disclosure of information: interpretation) for...
In section 24 (power to obtain information about income from...
TCGA 1992 is amended as follows.
In section 10(4) (persons exempt under Part 18 of ICTA)...
In section 10B(3) (companies exempt under Part 18 of ICTA)...
In section 59(2)(b) (arrangements giving relief for partnership gains) for...
In sections 140H(3), 140I(3) and 140J(3) (gains on which tax...
Omit section 277 (application to capital gains tax of provisions...
Omit section 278 (deduction for foreign gains tax in respect...
In section 288(1) (interpretation) for the definition of “double taxation...
FA 1993 is amended as follows.
Omit section 194 (application to petroleum revenue tax of provisions...
In section 29(7A) (discovery assessments: relaxation of pre-conditions) for “section...
In section 195(3) (interpretation of Part 3) omit “, other...
F(No.2) A 1997 is amended as follows.
(1) Amend section 30 (tax credits) as follows.
FA 1998 is amended as follows.
(1) Amend Schedule 18 (company tax returns etc) as follows....
FA 2000 is amended as follows.
(1) Amend Schedule 22 (tonnage tax) as follows.
CAA 2001 is amended as follows.
In section 105(4) (meaning of “double taxation arrangements”) for the...
ITEPA 2003 is amended as follows.
In section 43C(5) (meaning of consequential claim) for “or 43A”...
In section 643(6) in the definition of “double taxation relief...
FA 2004 is amended as follows.
In Chapter 7 of Part 3 (special withholding tax) omit—...
In section 189(3) (treatment of relevant UK earnings) for “by...
In Schedule 34 (non-UK pensions schemes: application of certain charges)...
ITTOIA 2005 is amended as follows.
In section 397A(7) (interpretation of section) in the definition of...
For section 397BA(2)(a) (which refers to arrangements to which section...
In section 763(3) (priority of double taxation arrangements) for “section...
(1) Section 764 (application of ICTA provisions about special relationships)...
In Part 4, after section 43C insert— Claims for double...
In section 858(1)(b) (resident partners and double taxation agreements) for...
ITA 2007 is amended as follows.
In section 1(2)(a) (example of income tax provisions located outside...
(1) Amend section 26(1)(b) (provisions referred to at Step 6...
In section 27(6) (tax reductions for individuals by way of...
In section 28(4) (tax reductions for non-individuals by way of...
(1) Amend section 29 (tax reductions: supplementary) as follows.
(1) Amend section 32 (liabilities not dealt with in calculation...
(1) Amend section 53 (transfer of unused relief: general) as...
(1) In section 424(2) (gift aid: charge to tax: interpretation)...
ICTA is amended as follows.
(1) Amend section 425 (“total amount of income tax” in...
In section 527(2) omit paragraph (b) (subsection (1) does not...
In section 582(2) (regulations may remove or reduce rights to...
In section 828C(4) (entitlement to double taxation relief)—
In section 849(1) (interaction between Part 15 of ITA 2007...
In section 1023 (meaning in Act of “double taxation arrangements”)...
In section 1026— (a) after paragraph (e) insert “ or...
FA 2008 is amended as follows.
In Schedule 17 in paragraph 10(3) after paragraph (c) insert...
CTA 2009 is amended as follows.
In section 444BB(6) (meaning of “double taxation relief”)—
In section 464(3)— (a) in paragraph (f) for “section 795(4)...
In section 486(2) for “section 811 of ICTA” substitute “...
In section 550(7) (meaning of “double taxation relief”) for “Part...
In section 697(3)(a) (exceptions to section 696) for “because of...
In section 782(1)(a) (intangible fixed assets transferred in the course...
In section 793(3)(b) (when election under section 792 may be...
In section 827(7) (no claim under section if claim made...
In section 906(3)— (a) omit “and” after paragraph (a), and...
For section 931C(1)(a) (which refers to arrangements to which section...
In section 931H(5) for “Part 18 of ICTA” substitute “...
The repeal of provisions and their enactment in a rewritten...
(1) This paragraph applies if, in the case of any...
(1) Sub-paragraph (2) applies to any arrangements—
Any arrangements specified in an Order in Council made under...
Section 11(3) does not have effect in relation to arrangements...
(1) Condition C in section 15 (credit for underlying tax...
(1) If article 10 of the 2009 Order applies—
In relation to distributions paid before 1 July 2009, the...
Section 34 does not have effect in relation to payments...
Section 45(2) has effect in relation to a credit for...
Section 49 has effect in relation to a credit for...
Paragraph 1 does not apply to any change made by...
In relation to dividends paid before 1 July 2009, section...
Section 65(3)(a) applies with the omission of sub-paragraph (ii) if...
(1) Section 109 does not apply in the case of...
Section 112(3) does not have effect in relation to payments...
In paragraph 5(4)(b) of Schedule 27 to ICTA (offshore funds:...
The amendments in sections 806A to 806J of ICTA that...
(1) Despite their repeal by this Act, the saved rules...
(1) Sub-paragraph (2) has effect for the purposes of applying...
Section 155(6)(b) does not have effect in relation to distributions...
(1) An agreement made before 27 July 1999 cannot have...
Any subordinate legislation or other thing which—
Sections 249 to 254 (tax arbitrage: receipt notices) do not...
(1) Part 7 of this Act does not have effect...
(1) An amount that would, apart from this paragraph, meet...
(1) Regulations under section 354 may not make provision about...
Paragraph 33 does not prevent regulations under section 354 making—...
In relation to periods of account (within the meaning given...
(1) If article 10 of the 2009 Order applies, section...
(1) The alternative finance provisions do not apply to purchase...
So far as Chapter 5 of Part 17 of ICTA...
(1) In relation to arrangements entered into before 15 October...
(1) Any reference (express or implied) in this Act, another...
(1) In relation to arrangements entered into before 15 October...
(1) Sub-paragraphs (2) and (3) apply if—
Chapter 5B of Part 13 of ITA 2007 (which is...
(1) In relation to a transfer before 22 April 2009,...
In relation to a transfer before 22 April 2009, section...
(1) Sections 925A to 925F and 926(1A) of ITA 2007...
(1) Any reference (express or implied) in any enactment, instrument...
Paragraphs 1 to 5 have effect instead of section 17(2)...
Paragraphs 4 and 5 apply only so far as the...
(1) The repeal by this Act of a transitional or...
(1) In this Part— “enactment” includes subordinate legislation (within the...
Unassessed transfer pricing profits: corporate partners
Appeal against assessment
Review of assessment
Settling of appeal by agreement
Introduction
Modifications to Parts 1 to 3 of this Schedule
Conditions for being assessed
Preliminary notices
Representations by the partnership
Assessment
Amendment of partnership return by partnership
Amendment of assessment by HMRC
No postponement except before assessment is finalised for tax on same profits
Closure notices: rules relating to period for amendments
Official guidance
Authoritative sources published by regulators or government explaining this legislation.
- Country-by-Country Reporting guidance (opens in a new tab) from HMRC Detailed Guidance
- HMRC Statement of Practice 1 (2010) - Transfer Pricing Methodology (opens in a new tab) from HMRC Publication
- HMRC guidance on OECD Transfer Pricing Guidelines (opens in a new tab) from HMRC Detailed Guidance
- HMRC International Manual - Transfer Pricing (opens in a new tab) from HMRC Detailed Guidance
Enforcement and responsible bodies
The regulators that administer or enforce this legislation.
HM Revenue & Customs
Tax collection, customs duties, national insurance, tax credits, and enforcement of the National Minimum Wage. Regulates all UK businesses for tax compliance …
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Regulators
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