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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 marginal relief thresholds

CTM03958 | Small profits rate: financial year 2023 onwards: examples - change in number of associated companies and a change in the marginal relief thresholds

From HM Revenue & Customs · Company Taxation Manual

Company C has an accounting period of 1 July 2030 to 30 June 2031, profits of £85,000 and two associated companies for the period to 31 March 2031 and one associated company for the three months to 30 June 2031. The CT main rate and small profits are unchanged at 25% and 19% respectively but the upper limit has been raised to £300,000.

Marginal relief fraction

The differential between the lower and upper limits has changed so the marginal relief fraction for Financial Year 2031 therefore becomes:

£50,000 x 19% = £9,500

£300,000 x 25% = £75,000

£250,000 x fraction = £65,500

£65,500/£250,000 = 26.2% marginal rate fraction

Difference between the main rate and the marginal rate expressed as a fraction is

26.2% - 25% = 1.2% = 3/250

As there is a change in the limits, the profits of the period are apportioned on a time basis by reference to the financial years as follows:

FY 30 = £85,000 x (274/365) = £63,808.22

FY 31 = £85,000 x (91/365) = £21,191.78

These apportioned profits are then compared with the relevant fractions of the lower and upper limits as follows:

FY30 – 3 associated companies in total

Lower limit £50,000/ 3 = £16,667 x (274/365) = £12,511.42

Upper limit £250,000/ 3 = £83,333 x (274/365) = £62,557.08

FY31 – 2 associated companies in total

Lower limit £50,000/2 = £25,000, apportioned £25,000 x (91/365) = £6,232.88

Upper limit £300,000/2 = £150,000, apportioned £150,000 x (91/365) = £37,397.26

The profits for FY30 exceed the thresholds so they are chargeable at the main rate without marginal relief.

£63,808.22 x 25% = £15,952.06

The profits fall between the thresholds for FY 31 so marginal relief applies as follows:

£21,192 x 25% = £5,298

Total = £21,250.06

Less marginal relief

FY 31 (£37,397 - £21,192) x 3/250 = 16,205 x 3/250 = (£194.46)

Total CT due = £21,055.56

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