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Contents

Official guidance
Company Taxation Manual

CTM08000 · Corporation Tax: management expenses

  • CTM08005 · Introduction
  • CTM08010 · Commencement and transitional provisions in FA04
  • CTM08020 · Investment company - status
  • CTM08030 · Investment company - principal part of income
  • CTM08040 · Investment company - with investment business
  • CTM08050 · Investment company - business of making investments: case law
  • CTM08060 · Company status - parent or holding companies
  • CTM08070 · Company status - cessation of trade
  • CTM08080 · Company status - liquidation
  • CTM08090 · Company status - housing associations
  • CTM08100 · Company status - investment funds
  • CTM08110 · Company status - development corporations
  • CTM08150 · General
  • CTM08160 · General - case law
  • CTM08170 · Wholly and exclusively
  • CTM08180 · Groups
  • CTM08190 · Changing investments - general test
  • CTM08200 · Take-over bid defence costs
  • CTM08210 · Avoidance and unallowable purpose - general
  • CTM08215 · Unallowable purpose
  • CTM08220 · Unallowable purpose - business or commercial purpose test
  • CTM08225 · Unallowable purpose - activities within the charge to tax
  • CTM08230 · Targeted anti-avoidance provision - introduction and commencement
  • CTM08232 · Targeted anti-avoidance provision (TAAR) - general
  • CTM08234 · Targeted anti-avoidance rule (TAAR) - purpose
  • CTM08235 · Targeted anti-avoidance rule (TAAR) - example of arrangements caught
  • CTM08236 · Targeted anti-avoidance rule (TAAR) - arrangements
  • CTM08238 · Targeted anti-avoidance rule (TAAR) - tax advantage
  • CTM08239 · Targeted anti-avoidance rule (TAAR) - outlying provisions
  • CTM08240 · Capital v revenue
  • CTM08250 · Capital exclusion - periods starting on or after 1 April 2004
  • CTM08260 · Capital exclusion - acquisitions and disposals - periods from 1 April 2004
  • CTM08300 · Raising finance
  • CTM08310 · Short interest
  • CTM08320 · Insurance premiums
  • CTM08330 · Directors' remuneration
  • CTM08340 · Pension contributions
  • CTM08360 · Employees' relocation expenses
  • CTM08370 · Employees seconded to charities
  • CTM08380 · Charity agencies payroll giving scheme
  • CTM08390 · Employee share schemes costs
  • CTM08400 · Redundancy payments
  • CTM08410 · Administrative costs
  • CTM08420 · Valuations
  • CTM08430 · Statutory provisions
  • CTM08440 · Property business
  • CTM08450 · Capital allowances on machinery and plant
  • CTM08455 · Capital allowances on structures and buildings
  • CTM08460 · Restrictive covenants
  • CTM08470 · Timing of deduction of emoluments
  • CTM08550 · Meaning of ‘disbursed’
  • CTM08560 · Timing of relief - periods from 1 April 2004
  • CTM08570 · Reversals
  • CTM08580 · Method of relief and computation
  • CTM08600 · Appeals
  • CTM08610 · Order of set-off
  • CTM08620 · Carry forward and group relief of excess expenses
  1. Corporation Tax: management expenses: contents
  2. Corporation Tax: management expenses: order of set-off

CTM08610 | Corporation Tax: management expenses: order of set-off

From HM Revenue & Customs · Company Taxation Manual

A company can be 'a company with investment business' within CTA09/S1218B and also carry on a trade. So a company may be entitled to management expenses under CTA09/S1219 and have trading losses available for relief under CTA10/S37.

Trading losses

Management expenses under CTA09/S1219 (but excluding carried-forward management expenses) must be deducted before any losses under CTA10/S37 may be set off. This is because:

  • the deduction of management expenses is mandatory in the computation of the total profits (CTM08580),

but

  • the company may make a claim for the set-off of trade losses against those profits.

Qualifying charitable donations

CTA10/S189 (1) and (2) allow the deduction of charges on income from a company’s total profits (as reduced by any other relief except group relief) in computing CT chargeable for an accounting period.

CTA10/S189 (4) allows the deduction only in respect of payments made by the company in the accounting period concerned and CTA10/S189 (3) limits the deduction to the amount that reduces the company’s total profits for the period to nil.

Any excess of qualifying charitable donations (that is, an amount that cannot be deducted under CTA10/S189 because there are insufficient total profits) is added to any excess management expenses of the period and is carried forward to the next accounting period and treated as an expense of management of that period.

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