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CTM90105 | CTSA: introduction: background

From HM Revenue & Customs · Company Taxation Manual

CTSA applies to companies for accounting periods ended on or after 1 July 1999.

CTSA imported the finality and enquiry rules of SA into the general administrative framework for corporation tax purposes.

It also brought into a single SA:

  • tax chargeable under CTA10/S455 on loans or advances by close companies to participators,

  • tax that was chargeable under ICTA88/S747 on the profits of controlled foreign companies for accounting periods ending on or before 31 December 2012.

You should read references in this guidance to ‘tax’ and to ‘CT’ accordingly, where the context requires.