Readers’ forum: Does date of disposal affect tax rate?

My client company has a September year end – so in the year to 30 September 2023 it will be affected by the change in corporation tax (CT) rates which come in on 1 April. The director has told me that the company is likely to realise a large capital gain at some point in the next few months but that there is some flexibility over the timing. He has asked me whether the company will pay the same rate of tax regardless of whether the disposal will be before or after 1 April.

The profits of a company for CT include its chargeable gains (CTA 2009 s 2(2)). Typically the profits are apportioned on a time basis where this straddles a financial year (CTA 2009 s 8 and CTA 2010 s 1172). Both s 8 and s 1172 are ‘subject to any contrary provision in the Corporation...