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Contents

Official guidance
International Manual

INTM610000 · Contents: Profit Fragmentation Rules

  • INTM610010 · Introduction
  • INTM610020 · Introduction: Who do these rules apply to? / How will these rules be used?
  • INTM610030 · Introduction: When do these rules apply?
  • INTM610040 · Parties
  • INTM610050 · Parties (Continued)
  • INTM610060 · Profit Fragmentation Arrangements
  • INTM610070 · Profit Fragmentation Arrangements: The Material Provision
  • INTM610080 · Profit Fragmentation Arrangements: Transfer of Value
  • INTM610090 · Profit Fragmentation Arrangements: Tracing Value
  • INTM610100 · Profit Fragmentation Arrangements: Arm’s Length Transfer
  • INTM610110 · Enjoyment Conditions
  • INTM610120 · Enjoyment Conditions: Enjoyment Test
  • INTM610130 · Enjoyment Conditions: Procurer Test
  • INTM610140 · Exception Conditions
  • INTM610150 · Exception Conditions: Tax Mismatch
  • INTM610160 · Exception Conditions: Tax Mismatch: Quantifying the Resident Party’s Tax Reduction
  • INTM610170 · Exception Conditions: Tax Mismatch: Qualifying Deduction and Qualifying Loss Relief
  • INTM610180 · Exception Conditions: Tax Mismatch: Hybrid and Transparent Entities/ Reasonable to Conclude/ UK Resident Non-Domiciled Individuals
  • INTM610190 · Exception Conditions: Tax Advantage Test
  • INTM610200 · Profit Fragmentation Adjustments
  • INTM610210 · Profit Fragmentation Adjustments: Hierarchy of Legislation
  • INTM610220 · Profit Fragmentation Adjustments: NICs Consequences for Individuals
  • INTM610230 · Profit Fragmentation Adjustments: Reimbursement Payments
  • INTM610240 · Double Taxation
  • INTM610250 · Interaction with Other Legislation: Income Chargeable to S720 or S727 ITA 2007
  • INTM610260 · Interaction with Other Legislation: Income Chargeable to S731 ITA 2007
  • INTM610270 · Interaction with Other Legislation: Carried Interest and Disguised Investment Management Fees
  • INTM610280 · Making Adjustment on the Tax Return: Individuals
  • INTM610290 · Making Adjustments on the Tax Return: Members of a partnership required to make adjustments under the Profit Fragmentation legislation
  • INTM610300 · Making Adjustments on the Tax Return: Companies required to make adjustments under the Profit Fragmentation legislation
  1. Contents: Profit Fragmentation Rules
  2. Making Adjustment on the Tax Return: Individuals

INTM610280 | Making Adjustment on the Tax Return: Individuals

From HM Revenue & Customs · International Manual

Customers will be required to determine whether the Profit Fragmentation legislation applies to them. If they determine that the Profit Fragmentation legislation does apply to them, they will need to make the adjustments required by paragraph 7 of the legislation. These pages set out how different types of customers to whom the Profit Fragmentation legislation could apply should make the required adjustments on their tax return. Customers to whom the Profit Fragmentation legislation applies, and who currently do not make a self-assessment return, must make a self-assessment return in order to report taxable income arising from the adjustment made under the Profit Fragmentation legislation.

Individuals operating as sole traders/ receiving UK property income required to make adjustments under the Profit Fragmentation legislation

Individuals who are self-employed (completing SA103F or SA103S)

Individuals required to adjust their self-employment income under paragraph 7 of the Profit Fragmentation legislation must record these adjustments on their SA return as follows.

Individuals who complete form SA103F must:

  • If the required adjustment consists of reducing an expense, disallow the relevant expense that was previously included in the return by making the appropriate entry in one of boxes 32-45.

  • If the required adjustment consists of increasing their income, increase their income by inserting the additional income figure in box 60.

Individuals who complete form SA103S must:

  • If the required adjustment consists of reducing an expense, take the relevant expense off the expense figure included in one of boxes 11-19 (and the total at box 20). If their annual turnover was such that they are only required to complete box 20, they should just take the relevant expense off the box 20 total figure.

  • If the required adjustment consist of increasing their income, increase their income by inserting the additional income figure at box 27.

Individuals who have UK property income (completing SA105)

Individuals required to adjust their UK property income under paragraph 7 of the Profit Fragmentation legislation must record these adjustments on their SA return (form SA105) as follows:

  • If the required adjustment consists of reducing an expense, take the relevant expense off the expense figure/s included in boxes 24-29.

  • If the required adjustment consists of increasing their income, increase their income by increasing the total income figure at box 20.

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