Corporation Tax - Lecture 8 Flashcards
Corporation tax =
Tax of profits of corporations (ltd/plc) or unincorporated association (club/ political association)
UK resident company liable to CT on
Worldwide income
UK resident company =
One registered in UK or has central control and decision making carried out in UK
Dividends received from other companies
Not liable to CT
Dividends paid
Not allowable trading expense
Classical tax system
- Company pays taxes on all profits whether distributed or not
- Shareholders independent of company (taxed twice)
Imputation tax system
Some tax imputed to shareholders to reduce income tax payable
TTP (taxable total profit) =
Income + Gains - Charges
CAP length
Anything up to 12 months (cannot exceed)
CAP starts when (3)
- Company begins to trade
- Company acquires source chargeable income
- Previous CAP ends
CAP ends when (4)
- 12 months after starts
- Date accounts made up to
- Date company ceases to trade/ winds up
- Date company ceases to be UK resident
Company’s rental income received and short lease premium income is assessable under
Property business profit
Expenses incurred as result renting property
Deductible
Interest paid on loan to purchase rental property
Not deducted as expense
Separate calculation needed
Each rental property
Interest income from trading vs non trading
Included in tax adjusted trading profit. (Non trading = TTP)
Overseas income
Profits made by overseas branch where branch controlled by overseas management.
If overseas branch controlled by UK management
Branch profits included in TTP
Election for exclusion branch profits within TTP
Covers all branches, irrevocable decision
Chargeable gains =
One-off gains on disposal capital assets
Indexation allowance =
0.XXX x cost on acquisition/ enhancement
Inflation adjustment
Indexation factor =
(RPI month disposal - RPI month acquisition/ enhancement) / RPI month acquisition/ enhancement
Negative Indexation factor
Cannot happen, if RPI falls, 0
Research and development basic treatment
Deduction of 230% R&D allowed (must be spending over £10,000)
Research and development basic treatment > loss situation
Can claim refundable credit £14.50 every £100 R&D expenditure
Research and development above the line
Credit 11% expenditure and offset against current year CT
Double taxation relief
Credit the lower of:
- Overseas tax suffered
- UK corporation tax attributable to overseas income
Payment quarterly installments
14th month for months 7, 10, 13, 16 accounting period. If taxable profits > £1.5m
Criticisms of classical system (3)
- Double taxation of earnings
- Not neutral between equity and debt capital
- Encourages retention of earnings > may inflate value of shares
Full imputation =
All CT imputed
Partial imputation =
Part of CT imputed