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More cold comfort

23 August 2011
Issue: 4318 / Categories: Forum & Feedback
No possibility of using ‘not carried on a business’ argument?

We have just encountered in practice the problems with CTA 2010, s 26 discussed in the article Cold comfort for corporates.

I am not sure we understand David Jeffery’s comment that the small profit rate can still be claimed even if the conditions in s 26 are not fully met: CTA 2010, s 25(6)(a) states that subsection (3) is subject to s 26.

Doesn’t this mean there is no possibility of using the ‘not carried on a business’ argument? If there is a legitimate way around this we would be very pleased to know.

Marion

Issue: 4318 / Categories: Forum & Feedback
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