³ÉÈËÓ°Òô

Basic principles


Who pays corporation tax?

Corporation tax is payable by 'companies', which includes any body corporate and unincorporated associations.

A company that is tax resident in the UK is generally subject to UK corporation tax on its worldwide profits. A company that is not tax resident in the UK may still be subject to UK corporation tax in certain circumstances, including:

  1. •

    (for disposals of UK land on or after 5 July 2016) in respect of profits from a trade of dealing in or developing UK land, (for more information, see Practice Note: Profits from trading in and developing UK land (transactions in UK land))

  2. •

    if it carries on a trade (other than a trade of dealing in or developing UK land) in the UK through a permanent establishment (PE), in which case it is subject to UK corporation tax in respect of the profits attributable to its UK PE (for more information, see Practice Notes: What is a UK permanent establishment? and How is a UK permanent establishment taxed?)

  3. •

    if it disposes (directly or indirectly—this includes a sale of shares in a property

To view the latest version of this document and thousands of others like it, sign-in with ³ÉÈËÓ°Òô or register for a free trial.

TAKE A FREE TRIAL
Powered by Lexis+®
Latest Tax News

FTT considers meaning of interest and decides that an element of redress payments constituted interest (NHS Mid & South Essex ICB and others v HMRC)

Tax analysis: In NHS Mid & South Essex ICB and others, the First-tier Tax Tribunal (FTT) decided that an element of the NHS continuing healthcare (CHC) redress payments constituted interest for the purposes of section 874 of the Income Tax Act 2007 (ITA 2007) and, furthermore, that the interest constituted yearly interest or was treated as yearly interest under ITA 2007, s 874(5A) since the interest was payable to individuals in respect of compensation.

Tax weekly highlights—19 December 2024

This week's edition of Tax weekly highlights includes: (1) the House of Commons committee debating (but not amending) clauses of the Finance Bill 2025, (2) the NICs Bill passing the House of Commons stages without amendment, and (3) the Spring Forecast to be published on 26 March 2025.

FTT applies carried-forward losses anti-avoidance rule (Blackfriars v HMRC)

Tax analysis: In Blackfriars Hotel (UK) Holdings Ltd, the First-tier Tax Tribunal (FTT) held that the anti-avoidance ‘loss refresh’ provisions of Part 14B of the Corporation Tax Act 2010 (CTA 2010) applied to disallow relief for pre-April 2017 carried forward loan relationship deficits against profits arising from tax arrangements entered into by the company.

UT sets aside FTT decision on tax treatment of EBT arrangements (M R Currell Ltd v HMRC)

Tax analysis: In M R Currell Ltd v HMRC, the Upper Tribunal (UT) considered an appeal of the taxpayer company against a decision of the First-tier Tax Tribunal (FTT) that a director and shareholder of the taxpayer company received taxable earnings in circumstances where the company had made a contribution to an employee benefit trust (EBT) which then subsequently loaned an equivalent amount to the shareholder director. The UT set aside the decision of the FTT and re-made it, allowing the taxpayer company’s appeal.

View Tax by content type :  
News
Practice notes
Precedents
Q&As

Popular documents

R&D capital allowances

R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D) reliefs, beginning with a consultation exploring the nature of current private sector R&D investment and the impact of existing R&D relief schemes. This

When would preference shares fall under the shares as debt rules and hence the dividend payments would

When would preference shares fall under the shares as debt rules and hence the dividend payments would fall to be taxed as debt as opposed to qualifying for the corporation tax exemption for dividend payments?The ‘shares as debt’ rules applied to shares held by companies up until 21 April 2009 (for

Capital gains—intra-group asset transfers

Capital gains—intra-group asset transfersSTOP PRESS—Impact of the Retained EU Law (Revocation and Reform) Act 2023: This document contains references to retained EU law (REUL) and associated terms introduced by the European Union (Withdrawal) Act 2018 in connection with Brexit. From 1 January 2024,

Amortisation of intangible fixed assets

Amortisation of intangible fixed assetsWhere a company acquires (or otherwise incurs capitalised expenditure upon) an intangible fixed asset that falls within the corporate intangible fixed asset regime (IFA regime):•no capital allowances are available in respect of that intangible fixed asset
R&D capital allowances

R&D capital allowances

R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D) reliefs, beginning with a consultation exploring the nature of current private sector R&D investment and the impact of existing R&D relief schemes. This

When would preference shares fall under the shares as debt rules and hence the dividend payments would

When would preference shares fall under the shares as debt rules and hence the dividend payments would

When would preference shares fall under the shares as debt rules and hence the dividend payments would fall to be taxed as debt as opposed to qualifying for the corporation tax exemption for dividend payments?The ‘shares as debt’ rules applied to shares held by companies up until 21 April 2009 (for

Capital gains—intra-group asset transfers

Capital gains—intra-group asset transfers

Capital gains—intra-group asset transfersSTOP PRESS—Impact of the Retained EU Law (Revocation and Reform) Act 2023: This document contains references to retained EU law (REUL) and associated terms introduced by the European Union (Withdrawal) Act 2018 in connection with Brexit. From 1 January 2024,

Amortisation of intangible fixed assets

Amortisation of intangible fixed assets

Amortisation of intangible fixed assetsWhere a company acquires (or otherwise incurs capitalised expenditure upon) an intangible fixed asset that falls within the corporate intangible fixed asset regime (IFA regime):•no capital allowances are available in respect of that intangible fixed asset