CTM08800 - Corporation Tax: change of ownership: companies with investment business: apportionment of ‘amounts in issue’
Source: gov.uk (2025-07-18)


CTA10/S685 and S686

The amounts in issue for which an apportionment is required under CTA10/S678 (CTM08770 (https://www.gov.uk/hmrc-internal-manuals/company-taxation-manual/ctm08770)) are listed at CTA10/S685. The amounts, and the manner of apportionment, are as follows:

1

The amount for the true accounting period (AP) of any adjusted non-trading profits from the company's loan relationships (see CTA10/S686 (2))

Apportion on a time basis according to the respective lengths of the two notional APs

2

The amount for the true AP of any adjusted non-trading deficit from the company's loan relationships (see S686 (3))

Apportion on a time basis according to the respective lengths of the two notional APs

3

The amount of any non-trading debit that falls to be brought into account for the true AP for the purposes of CTA09/PART5 (loan relationships) in respect of any debtor relationship of the company

(1) If condition A in S686 (4) is met, apportion by reference to the time of accrual of the amount to which the debit relates

(2) If condition B in S686 (5) is met, apportion to the first notional AP

4

The amount of any non-trading deficit carried forward to the true AP under CTA09/S457 (1), S463G (6) or S463H (4)

Apportion the whole of the amount to the first notional AP

5

The amount of any non-trading credits or debits in respect of intangible fixed assets that fall to be brought into account for the true AP under CTA09/S751 (non-trading gains and losses), but excluding any amount within 6 below

Apportion to each notional AP the credits or debits that would fall to be brought into account in that period if it were a period of account for which accounts were drawn up in accordance with generally accepted accounting practice (GAAP).

6

The amount of any non-trading loss on intangible fixed assets carried forward to the true AP under CTA09/S753 (3) and treated under that section as if it were a non-trading loss on intangible fixed assets for that period

Apportion the whole of the amount to the first notional AP

7

The amount of any expenses of management referable to the true AP within the meaning of CTA09/PART16/CHAPTER2 (companies with investment business) - but see CTA10/S686 (6))

Apportion to each notional accounting period the amounts that would fall to be brought into account in that period as a if it were a period of account for which accounts were drawn up in accordance with generally accepted accounting practice (GAAP)

8

The amount of any excess carried forward under CTA09/S1223 (expenses of management carried forward) to the true AP

Apportion the whole of the amount to the first notional AP

9

The amount of any allowances falling to be made for the true AP as a result of CAA01/S253 which would (but for this provision) be added to the expenses of management for the period under CTA09/S1233 (excess capital allowances)

Apportion the amount on a time basis according to the respective lengths of the two notional APs

10

Any other amounts by reference to which the profits or losses of the true AP would be calculated

Apportion the amount on a time basis according to the respective lengths of the two notional APs

If any method of apportionment would work unjustly or unreasonably, any other method that is just and reasonable may be used