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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 and a change in the CT rates

CTM03957 | Small profits rate: financial year 2023 onwards: examples - change in number of associated companies and a change in the CT rates

From HM Revenue & Customs · Company Taxation Manual

Company B with an accounting period 1 January 2028 to 31 December 2028 has profits of £45,000. It has two associated companies in the period to 31 March 2028 and four in the period to 31 December 2028. Assume that the CT main rate increases from 25% to 26% for FY 2028 and the Small Profits Rate increases to 20%. There is no change in the marginal relief thresholds.

Once again, the accounting period straddles the financial year but, even though there is a change in the rate, the lower and upper limits have not changed, so there is no need to treat the period as two separate accounting periods for marginal relief purposes simply because the number of associated companies has changed throughout the year. However, the profits will be apportioned up to and from the rate change date.

There are four associated companies throughout the accounting period so the marginal relief thresholds will need to be proportionately reduced to see if marginal relief is available.

Lower limit £50,000/ 5 = £10,000

Upper limit £250,000/ 5 = £50,000

The £45,000 profits fall between the thresholds so marginal relief applies and is calculated as follows:

The profits are apportioned between the financial years (2028 is a leap year so the denominator is 366):

FY 2027 £45,000 x 91/366 = £11,189 x 25% = £2,797.25

FY 2028 £45,000 x 275/366 = £33,811 x 26% = £8,790.86

Total £11,588.11

Less marginal relief

(£50,000 - £45,000) x 3/200 = (£75)

Total CT due = £11,513.11

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