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Legislation
Corporation Tax Act 2009

Part 18 Unremittable income

  • Section 1274 Unremittable income: introduction
  • Section 1275 Claim for relief for unremittable income
  • Section 1276 Withdrawal of relief
  • Section 1277 Income charged on withdrawal of relief after source ceases
  • Section 1278 Valuing unremittable income
  1. Part 18 · Unremittable income
  2. Income charged on withdrawal of relief after source ceases

Section 1277 | Income charged on withdrawal of relief after source ceases

From legislation.gov.uk

(1)This section applies if—

(a)income is treated as arising as a result of section 1276, and

(b)at the time it is so treated the company which would have become liable for corporation tax as a result of that section—

(i)has permanently ceased to carry on the trade or property business from which the income arises, or

(ii)in the case of income from another source, has ceased to possess that source.

(2)In the case of income from a trade—

(a)the income is treated as a post-cessation receipt for the purposes of Chapter 15 of Part 3 (trading income: post-cessation receipts), but

(b)in the application of that Chapter to that income, section 189 (extent of charge to tax) is omitted.

(3)In the case of income from a property business—

(a)the income is treated as a post-cessation receipt from a UK property business for the purposes of Chapter 9 of Part 4 (property income: post-cessation receipts), but

(b)in the application of that Chapter to that income, section 281 (extent of charge to tax) is omitted.

(4)In the case of income from another source, the income is taxed as if the company continued to possess that source.

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