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Legislation
Corporation Tax Act 2009

Chapter 17 Priority rules

  • Section 464 Priority of this Part for corporation tax purposes
  • Section 465 Exclusion of distributions except in tax avoidance cases
  1. Chapter 17 · Priority rules
  2. Priority of this Part for corporation tax purposes

Section 464 | Priority of this Part for corporation tax purposes

From legislation.gov.uk

(1)The amounts which are brought into account in accordance with this Part in respect of any matter are the only amounts which may be brought into account for corporation tax purposes in respect of it.

(2)Subsection (1) is subject to any express provision to the contrary.

(3)For further provisions relating to the rule in this section, see in particular—

(a)section 445(2) (disapplication of section 444 where Part 4 of TIOPA 2010 applies),

(b)section 465 (exclusion of distributions except in tax avoidance cases),

(c)section 700 (relationship of Part 7 to this Part),

(d)section 96(4) of CTA 2010 (write-off of government investment),

(e)sections 286 to 287A of CTA 2010 (oil activities: loan relationships),

(f)section 31(5) of TIOPA 2010 (computation of income subject to foreign tax),

(g)section 112(5) of TIOPA 2010 (deduction for foreign tax where no credit available),

(h)... and

(i)section 640(2) of CTA 2010 (banks etc in compulsory liquidation: taxation of certain receipts).

(4)See also the following sections (under which amounts prevented from being brought into account under this Part are treated as if they were so brought into account for the purposes of this section)—

(a)section 327(5) and (6) (disallowance of imported losses etc), ...

(b)section 441(4) and (5) (loan relationships for unallowable purposes) , and

(c)section 455A(3) (debits arising from derecognition of creditor relationships).

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