Pro-Forma Corporation Tax Computation R&D Expenditure additional relief, can deduct Group Relief Group 75% group, e.g a 75% subsidiary
Name of company additional 130% of qualifying expenditure (SME’s) or 2 75% subs with same parent, surrender losses to
Corporation tax computation for AP ended: Above the tax line credit profitable group members to utilise against TTP in same
Amortisation/Impairment to goodwill not allowable period
Trading Profits x Surrendering company claimant company
Less Capital Allowances (x) Rollover Relief Capital losses cannot be surrendered
Interest Income x R&D Tax Credits
Misc. Income x Transfer Pricing Corresponding accounting periods
Chargeable Gains (deduct losses) x Arms length price which might have been expected Max group relief lower of:
Total Profits x if the parties had been independent persons dealing A Ltd TTP in corresponding period
Less: Qualifying Charitable Donations (x) with each other in a normal commercial manner B Ltd Loss in corresponding period
Corporation Tax Liability @ 19% x Then TTP minus group relief
Less: DTR (x)
Corporation Tax Payable @ 19% xx
Corporation c/f group relief available
Due 9 months and 1 day after the end of AP Tax Consortium Relief
(unless large)
2 or more companies between them own at least 75% of
Financial year is 1st Apr – 31st March Corporation Tax Losses another company (more than 5% but less than 75%)
Dividends exempt Pro-forma computation: Investing company consortium member
UK Resident CT on worldwide assets Trading Income x Target company consortium company
Non-resident companies UK income and gains Other Income x Losses surrendered from company to members
if trading through UK branch or agency Net Chargeable Gains x Downwards up to their % of TTP (% x subsidiary profit)
Total Profits x
Annual Investment Allowance £1million for a Less: cp/cb/cf losses (x) Max relief Lower of:
max of 12 months (spit between related Less: QCDs (x) -Available TTP of members
companies, in any way) TTP x -% sharing of loss
Interest Income
Overseas Income included in TTP Capital Gains Groups owning 75% or more of subs
Current period claimed against total profits before
Property Income share capital , two subs owned >/75%
QCD’s) then:
QCD Allowable Asset sold to another gains group member no
Carry back preceding 12 months (profit before QCD)
Indexation Allowance (Movement on RPI) gain/loss
Carry fwd automatically c/f if excess losses remain,
Assets acquired before December 2017): Receiving company base cost + indexation
profits can only be reduced by 50%
Gain/loss arising in an a/p can be transferred
Sales Proceeds Degrouping charge asset transferred at NGNL, within
-Capital losses can only be relieved against current or
Less: Cost 6 years the shares of recipient are sold, still owns asset
future chargeable gains
Unindexed gain Proceeds less Degrouping charge = cost
Less: Indexation allowance Restrictions on loss relief:
Indexed Gain Substantial Shareholding Exemption Trading
-Trade becomes small or negligible (only c/f)
Less: Rollover Relief company, >10% shares held for 12 months in 6 years
-Profits excess of £5M
, -Chargeable disposals of chargeable assets by Disposals between connected persons Business Asset Disposal Relief Individual can
chargeable persons Spouses/civil partners no chargeable gain claim on qualifying businesses (e.g sole trader)
-Chargeable disposal sale/gift of an asset, exchange Sister/brother chargeable gain -Investments do not qualify, must b disposed of as
of an asset, loss of an asset, compensation Connected persons @ MV going concern
-Exemptions disposals/gifts to charities Residential property not exempt, taxed -Disposal of shares 5% holding, trading company, 2
years, employee/director
Pro-Forma Capital Gains Chattels tangible, moveable property First £1m taxed @ 10% anything above @ 10/20%
Proceeds Wasting assets life less than 50 years (exempt) AEA deducted first
Less: Reliefs Non-wasting greater than 50 years, chargeable
Capital losses b/f Process and costs less than £6,000 are exempt Rollover relief selling a qualifying business asset
Trade Losses at a gain and reinvesting the net sale proceeds in a
Taxable gains Leases long lease (normal CGT way), short lease replacement business asset within the qualifying
Less: AEA (cost is depreciated) original cost x X/Y period – Balancing figure between taxable now
CGT Payable (proceeds net reinvested) and gain
Shares and Securities
-Payment due by 31 January following end of tax yar All chargeable except listed government securities, Enterprise Investment Scheme
-UK residential property payments on a/c due qualifying corporate bonds, ISA shares - Disposing of a chargeable asset giving rise to a gain
within 30 days of disposal Bonus issue free shares, to existing shareholders, and reinvesting the proceeds in qualifying shares
in proportion for shareholding -Qualify subscribe in cash, not be an
-Allowable capital losses in tax year are deducted from employee/director, have less than 30% interest
Rights issue offer of new shares @ discount to MV
gains in same tax year -Income tax relief @ 30% x cost of shares
Quoted shares gifted valued at mid-price:
-B/f losses deducted after AEA -Max investment - £1m = £300k reducer
Low x ½ x (high – low)
-Split gains between res. Prop and non-res. Prop -CGT exempt if held for 3 years
Matching rules same day, next 3 days, share pool
-Losses in year of death c/b 3 years LIFO basis -Inheritance qualify for BPR if held for 2 years
Part Disposals: Private Residence Relief (PPR)
Original Cost x A / (A + B) A = MV disposed of Disposal of UK residential property chargeable Gift Relief e.g lifetime gifts, agricultural property
B = MV of remainder Occupying house whole period gain exempt Use MV as proceeds trade, CBA/CA
-Deduct this from proceeds Part let out letting relief:
Gain x (periods of occupation/total period of Incorporation Relief Assets disposed by
Investors Relief Selling shares then subscribing for ownership) unincorporated business to company, net gains
new shares in unlisted trading company, held for 3 Business use not exempt deferred into share consideration, automatic,
years, rate of 10%, after 17 March 2016 Last 9 months = deemed occupation = exempt conditions – all assets transferred, going concern,
consideration whole/partly shares
Stamp Duty Land Tax Enterprise Investment Scheme Deferral = Gain x MV Shares received/MV total con.
Transfer of UK land & property -Encourage investors to subscribe for new shares in
Charged on non-residential property unquoted trading companies SEIS Reinvestment Relief Disposing of chargeable
0% £150k -Income tax relief @ 30% x cost of shares asset, giving gain which is reinvested in qualifying
2% Next £150k - £250k -Max investment - £1m = £300k reducer SEIS shares Max exemption 50% of the lower of
5% Next £250k and above -CGT exempt if held for 3 years gain amount and amount reinvested (max £50K)
Name of company additional 130% of qualifying expenditure (SME’s) or 2 75% subs with same parent, surrender losses to
Corporation tax computation for AP ended: Above the tax line credit profitable group members to utilise against TTP in same
Amortisation/Impairment to goodwill not allowable period
Trading Profits x Surrendering company claimant company
Less Capital Allowances (x) Rollover Relief Capital losses cannot be surrendered
Interest Income x R&D Tax Credits
Misc. Income x Transfer Pricing Corresponding accounting periods
Chargeable Gains (deduct losses) x Arms length price which might have been expected Max group relief lower of:
Total Profits x if the parties had been independent persons dealing A Ltd TTP in corresponding period
Less: Qualifying Charitable Donations (x) with each other in a normal commercial manner B Ltd Loss in corresponding period
Corporation Tax Liability @ 19% x Then TTP minus group relief
Less: DTR (x)
Corporation Tax Payable @ 19% xx
Corporation c/f group relief available
Due 9 months and 1 day after the end of AP Tax Consortium Relief
(unless large)
2 or more companies between them own at least 75% of
Financial year is 1st Apr – 31st March Corporation Tax Losses another company (more than 5% but less than 75%)
Dividends exempt Pro-forma computation: Investing company consortium member
UK Resident CT on worldwide assets Trading Income x Target company consortium company
Non-resident companies UK income and gains Other Income x Losses surrendered from company to members
if trading through UK branch or agency Net Chargeable Gains x Downwards up to their % of TTP (% x subsidiary profit)
Total Profits x
Annual Investment Allowance £1million for a Less: cp/cb/cf losses (x) Max relief Lower of:
max of 12 months (spit between related Less: QCDs (x) -Available TTP of members
companies, in any way) TTP x -% sharing of loss
Interest Income
Overseas Income included in TTP Capital Gains Groups owning 75% or more of subs
Current period claimed against total profits before
Property Income share capital , two subs owned >/75%
QCD’s) then:
QCD Allowable Asset sold to another gains group member no
Carry back preceding 12 months (profit before QCD)
Indexation Allowance (Movement on RPI) gain/loss
Carry fwd automatically c/f if excess losses remain,
Assets acquired before December 2017): Receiving company base cost + indexation
profits can only be reduced by 50%
Gain/loss arising in an a/p can be transferred
Sales Proceeds Degrouping charge asset transferred at NGNL, within
-Capital losses can only be relieved against current or
Less: Cost 6 years the shares of recipient are sold, still owns asset
future chargeable gains
Unindexed gain Proceeds less Degrouping charge = cost
Less: Indexation allowance Restrictions on loss relief:
Indexed Gain Substantial Shareholding Exemption Trading
-Trade becomes small or negligible (only c/f)
Less: Rollover Relief company, >10% shares held for 12 months in 6 years
-Profits excess of £5M
, -Chargeable disposals of chargeable assets by Disposals between connected persons Business Asset Disposal Relief Individual can
chargeable persons Spouses/civil partners no chargeable gain claim on qualifying businesses (e.g sole trader)
-Chargeable disposal sale/gift of an asset, exchange Sister/brother chargeable gain -Investments do not qualify, must b disposed of as
of an asset, loss of an asset, compensation Connected persons @ MV going concern
-Exemptions disposals/gifts to charities Residential property not exempt, taxed -Disposal of shares 5% holding, trading company, 2
years, employee/director
Pro-Forma Capital Gains Chattels tangible, moveable property First £1m taxed @ 10% anything above @ 10/20%
Proceeds Wasting assets life less than 50 years (exempt) AEA deducted first
Less: Reliefs Non-wasting greater than 50 years, chargeable
Capital losses b/f Process and costs less than £6,000 are exempt Rollover relief selling a qualifying business asset
Trade Losses at a gain and reinvesting the net sale proceeds in a
Taxable gains Leases long lease (normal CGT way), short lease replacement business asset within the qualifying
Less: AEA (cost is depreciated) original cost x X/Y period – Balancing figure between taxable now
CGT Payable (proceeds net reinvested) and gain
Shares and Securities
-Payment due by 31 January following end of tax yar All chargeable except listed government securities, Enterprise Investment Scheme
-UK residential property payments on a/c due qualifying corporate bonds, ISA shares - Disposing of a chargeable asset giving rise to a gain
within 30 days of disposal Bonus issue free shares, to existing shareholders, and reinvesting the proceeds in qualifying shares
in proportion for shareholding -Qualify subscribe in cash, not be an
-Allowable capital losses in tax year are deducted from employee/director, have less than 30% interest
Rights issue offer of new shares @ discount to MV
gains in same tax year -Income tax relief @ 30% x cost of shares
Quoted shares gifted valued at mid-price:
-B/f losses deducted after AEA -Max investment - £1m = £300k reducer
Low x ½ x (high – low)
-Split gains between res. Prop and non-res. Prop -CGT exempt if held for 3 years
Matching rules same day, next 3 days, share pool
-Losses in year of death c/b 3 years LIFO basis -Inheritance qualify for BPR if held for 2 years
Part Disposals: Private Residence Relief (PPR)
Original Cost x A / (A + B) A = MV disposed of Disposal of UK residential property chargeable Gift Relief e.g lifetime gifts, agricultural property
B = MV of remainder Occupying house whole period gain exempt Use MV as proceeds trade, CBA/CA
-Deduct this from proceeds Part let out letting relief:
Gain x (periods of occupation/total period of Incorporation Relief Assets disposed by
Investors Relief Selling shares then subscribing for ownership) unincorporated business to company, net gains
new shares in unlisted trading company, held for 3 Business use not exempt deferred into share consideration, automatic,
years, rate of 10%, after 17 March 2016 Last 9 months = deemed occupation = exempt conditions – all assets transferred, going concern,
consideration whole/partly shares
Stamp Duty Land Tax Enterprise Investment Scheme Deferral = Gain x MV Shares received/MV total con.
Transfer of UK land & property -Encourage investors to subscribe for new shares in
Charged on non-residential property unquoted trading companies SEIS Reinvestment Relief Disposing of chargeable
0% £150k -Income tax relief @ 30% x cost of shares asset, giving gain which is reinvested in qualifying
2% Next £150k - £250k -Max investment - £1m = £300k reducer SEIS shares Max exemption 50% of the lower of
5% Next £250k and above -CGT exempt if held for 3 years gain amount and amount reinvested (max £50K)
