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Official guidance
Company Taxation Manual

CTM03900 · Corporation Tax: small profits rate: financial year 2023 onwards

  • CTM03905 · Small profits rate: financial year 2023 onwards: introduction
  • CTM03910 · Small profits rate: financial year 2023 onwards: rates, limits and fractions
  • CTM03915 · Small profits rate: financial year 2023 onwards: definition of augmented profits
  • CTM03920 · Small profits rate: financial year 2023 onwards: no associated companies: profits not exceeding the lower limit
  • CTM03925 · Small profits rate: financial year 2023 onwards: no associated companies: profits exceeding the lower limit: marginal relief
  • CTM03930 · Small profits rate: financial year 2023 onwards: no associated companies: accounting period less than 12 months
  • CTM03935 · Small profits rate: financial year 2023 onwards: company with associated companies
  • CTM03940 · Small profits rate: financial year 2023 onwards: associated company definition: introduction
  • CTM03941 · Small profits rate: financial year 2023 onwards: associated company definition: control by the same person or persons
  • CTM03942 · Small profits rate: financial year 2023 onwards: associated company definition: association by holding fixed rate preference shares
  • CTM03943 · Small profits rate: financial year 2023 onwards: associated company definition: association through a loan creditor
  • CTM03944 · Small profits rate: financial year 2023 onwards: associated company definition: association through a trustee
  • CTM03945 · Small profits rate: financial year 2023 onwards: associated company definition: exclusions
  • CTM03948 · Small profits rate: financial year 2023 onwards: associated company definition: attribution to persons of rights and powers of their partners
  • CTM03949 · Small profits rate: financial year 2023 onwards: attribution to persons of rights and powers of their partners: commercial interdependence with companies controlled by associates
  • CTM03950 · Small profits rate: financial year 2023 onwards: substantial commercial interdependence: financial, economic and organisational links
  • CTM03951 · Small profits rate: financial year 2023 onwards: close investment holding companies
  • CTM03955 · Small profits rate: financial year 2023 onwards: accounting period straddling financial year - differing relevant amounts or limits
  • CTM03956 · Small profits rate: financial year 2023 onwards: examples - change in number of associated companies but no change in rates or thresholds
  • CTM03957 · Small profits rate: financial year 2023 onwards: examples - change in number of associated companies and a change in the CT rates
  • CTM03958 · Small profits rate: financial year 2023 onwards: examples - change in number of associated companies and a change in the marginal relief thresholds
  1. Corporation Tax: small profits rate: financial year 2023 onwards
  2. Small profits rate: financial year 2023 onwards: examples - change in number of associated companies but no change in rates or thresholds

CTM03956 | Small profits rate: financial year 2023 onwards: examples - change in number of associated companies but no change in rates or thresholds

From HM Revenue & Customs · Company Taxation Manual

Company A with an accounting period 1 October 2023 to 30 September 2024 has profits of £55,000. It has one associated company for the first half of the accounting period and two for the second half. Its CT liability is calculated as follows.

The accounting period straddles the financial year but, as there is no change in the rate or the lower and upper limits, there is no need to apportion the profits because the number of associated companies has changed throughout the year. CTA10/S18E (2) confirms that companies are treated as associated companies for the whole period even if they are associated for only part of it.

The upper and lower thresholds are adjusted for the number of associated companies as follows:

Lower limit £50,000/ 3 = £16,667

Upper limit £250,000/ 3 = £83,333

CT computation

The £55,000 profits fall between the thresholds so marginal relief applies.

£55,000 x 25% = £13,750

Less marginal relief

(£83,333 - £55,000) x 3/200 = (£425)

CT liability = £13,325

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