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House of Commons

Session 2009 - 10 Internet Publications Other Bills before Parliament

Corporation Tax Bill

Corporation Tax Bill xxxiv
Appeals
750    Appeals against counteraction notices
Interpretation
751    Interpretation of Part
Part 16
Factoring of income etc
Chapter 1
Transfers of income streams
752    Application of Chapter
753    Value of transferred income stream treated as income
754    Exception: amount otherwise taxed
755    Exception: transfer by way of security
756    Partnership shares
757    Interpretation of Chapter
Chapter 2
Finance arrangements
Type 1 arrangements
758    Type 1 finance arrangement defined
759    Certain tax consequences not to have effect
760    Payments treated as borrower’s income
761    Deemed loan relationship if borrower is a company
762    Deemed loan relationship if borrower is partnership with corporate member
Type 2 arrangements
763    Type 2 finance arrangement defined
764    Relevant change in relation to partnership
765    Certain tax consequences not to have effect
766    Deemed loan relationship
Type 3 arrangements
767    Type 3 finance arrangement defined
768    Certain tax consequences not to have effect
769    Deemed loan relationship
Exceptions
770    Exceptions: preliminary
771    Exceptions
772    Exceptions: relevant person
773    Power to make further exceptions
Corporation Tax Bill xxxv
Supplementary
774    Accounts
775    Arrangements
776    Assets
Chapter 3
Loan or credit transactions
777    Loan or credit transaction defined
778    Certain payments treated as interest
779    Tax charged on income transferred
Part 17
Manufactured payments and repos
Chapter 1
Introduction
780    Overview of Part
781    Key definitions
Chapter 2
Manufactured dividends
782    Meaning of “manufactured dividend”
783    Treatment of payer of manufactured dividend
784    Treatment of recipient of manufactured dividend
785    Treatment of payer: Real Estate Investment Trusts
786    Treatment of recipient: Real Estate Investment Trusts
787    Exemption of manufactured dividends
788    Statements about manufactured dividends
789    Powers about administrative provisions
Chapter 3
Manufactured overseas dividends
790    Meaning of “manufactured overseas dividend”
791    Treatment of payer of manufactured overseas dividend
792    Company receiving manufactured overseas dividend from UK resident etc
793    Section 792: amount treated as withheld
794    Company receiving manufactured overseas dividend from foreign payer
795    Exemption of manufactured overseas dividends
Corporation Tax Bill xxxvi
Chapter 4
Further provision about manufactured payments
Manufactured payments exceeding, or less than, underlying payments
796    Manufactured dividends: amounts exceeding underlying payments
797    Manufactured overseas dividends: amounts exceeding underlying payments
798    Manufactured overseas dividends less than underlying payments
Manufactured payments under arrangements with unallowable purpose
799    Manufactured payments under arrangements with unallowable purpose
800    Arrangements with an unallowable purpose
801    Sections 799 and 800: supplementary
Miscellaneous
802    Powers about amounts representative of overseas dividends
803    Power to deal with special cases
804    Regulation-making powers: general
Chapter 5
Stock lending arrangements and repos
Interpretation
805    “Stock lending arrangement”
806    Section 805: supplementary
807    “Creditor repo”, “creditor quasi-repo”, “debtor repo” and “debtor quasi-repo”
Tax credits: stock lending arrangements and repos
808    No tax credits for borrower under stock lending arrangement
809    No tax credits for lender under creditor repo or creditor quasi-repo
810    No tax credits for borrower under debtor repo or debtor quasi-repo
811    Arrangements between companies to make distributions
Deemed manufactured payments
812    Deemed manufactured payments: stock lending arrangements
Chapter 6
Interpretation of Part
813    The gross amount of a manufactured overseas dividend etc
814    Other interpretation
Corporation Tax Bill xxxvii
Part 18
Transactions in land
Introduction
815    Introduction to Part
816    Meaning of disposing of land
817    Priority of other tax provisions
Charge to tax on gains from transactions in land
818    Charge to tax on gains from transactions in land
819    Gains obtained from land disposals in some circumstances
820    Person obtaining gain
821    Company chargeable
822    Method of calculating gain
Further provisions relevant to the charge
823    Transactions, arrangements, sales and realisations relevant for Part
824    Tracing value
825    Meaning of “another person”
826    Valuations and apportionments
Exemptions
827    Gain attributable to period before intention to develop formed
828    Disposals of shares in companies holding land as trading stock
Recovery of tax
829    Cases where consideration receivable by person not assessed
830    Certificates of tax paid etc
Clearances and power to obtain information
831    Clearance procedure
832    Power to obtain information
Interpretation
833    Interpretation of Part
Corporation Tax Bill xxxviii
Part 19
Sale and lease-back etc
Chapter 1
Payments connected with transferred land
Introduction
834    Overview of Chapter
Application of the Chapter
835    Transferor or associate becomes liable for payment of rent
836    Transferor or associate becomes liable for payment other than rent
837    Relevant corporation tax relief
Relief (other than for certain insurance company expenses): restriction and carrying forward
838    Relevant corporation tax relief: deduction not to exceed commercial rent
Insurance company expenses: restriction and carrying forward of relief
839    Deduction under section 76 of ICTA not to exceed commercial rent
840    Carrying forward parts of payments
841    Aggregation and apportionment of payments
842    Payments made for later periods
Interpretation etc
843    Exclusion of service charges etc
844    Commercial rent: comparison with rent under a lease
845    Commercial rent: comparison with payments other than rent
846    Lease and rent
847    Associated persons
848    Land outside the UK
Chapter 2
New lease of land after assignment or surrender
Introduction
849    Overview of Chapter
Application of the Chapter
850    New lease after assignment or surrender
Taxation of consideration
851    Taxation of consideration
852    Position where new lease does not include all original property
Corporation Tax Bill xxxix
Relief for rent under new lease
853    Relief for rent under new lease
New lease treated as ending
854    New lease treated as ending
855    Position where rent reduces
856    Position where lease may be ended
857    Position where lease may be varied
858    Lease treated as ending: rentcharge
Lease varied to provide for increased rent
859    Lease varied to provide for increased rent
Interpretation
860    Relevant corporation tax relief
861    Linked persons
862    Lease, lessee, lessor and rent
Chapter 3
Leased trading assets
Introduction
863    Overview of Chapter
Application of the Chapter
864    Leased trading assets
Relief: restriction and carrying forward
865    Tax deduction not to exceed commercial rent
866    Long funding finance leases
867    Commercial rent
Interpretation
868    Lease
869    Relevant asset
Chapter 4
Leased assets: capital sums
Introduction
870    Overview of Chapter
Corporation Tax Bill xl
Application of the Chapter
871    Application of the Chapter
872    Payment under lease
873    Sum obtained
Charge to corporation tax
874    Charge to corporation tax
875    Hire-purchase agreements
876    Adjustments where sum obtained before payment made
Obtaining of sum
877    Sum obtained in respect of interest
878    Sum obtained in respect of lessee’s interest
879    Disposal of interest to associate
Apportionment
880    Apportionment of payments made and of sums obtained
881    Manner of apportionment
Interpretation
882    Associates
883    Capital sum
884    Lease
885    Relevant asset
886    Relevant tax relief
Part 20
Tax avoidance involving leasing plant or machinery
Chapter 1
Restrictions on use of losses in leasing partnerships
887    When restrictions on leasing partnership losses under this Chapter apply
888    Restrictions on leasing partnership losses
889    Interpretation of Chapter
Chapter 2
Capital payments in respect of leases treated as income
890    Capital payments in respect of leases treated as income
891    Apportionments for leases of plant or machinery and other property
892    Deduction where failure to make relevant capital payment expected
893    Meaning of “capital payment”, “relevant capital payment” etc
894    Other interpretation of Chapter

© Parliamentary copyright 2009	Revised 19 November 2009

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