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Cold comfort for corporates

26 July 2011 / David Jeffery
Issue: 4314 / Categories: Comment & Analysis , Companies

DAVID JEFFERY warns of the perils of ignoring the relevant factors when calculating small companies relief

KEY POINTS

  • The extent of the small companies rate and its value.
  • Dormant companies can be ignored under CTA 2010 s 26.
  • The restrictive conditions of s 26.
  • A comparison of SP 5/94 and s 26.
  • Some suggestions for the future.

The corporation tax small profits rate (as the small companies rate is now called in CTA 2010) matters. It matters because it is potentially a valuable relief. It matters also because claims to relief are routinely challenged by HMRC and the resulting settlement can be expensive – particularly if there is an opportunity for the inspectors to go back over past years.

Of course the...

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