Corporation Tax
Companies that are
resident in the
UK are subject to CT on their profits (income plus gains) arising in an
accounting period. An accounting period cannot be more than 12 months.
Company accounts prepared for a period of more than 12 months are
apportioned between the first 12 months and the remainder. Non-resident
companies may be subject to CT where they trade in the
UK through
a permanent establishment.
- A
company incorporated in the
UK is treated as
UK resident.
-
-
- A
non-UK incorporated company is treated as resident in the
UK if its central management and
control is exercised in the
UK.
Taxable
profits The amounts of income and capital gains are
basically determined by the tax rules that apply to individuals. Companies
are subject to many special rules and qualify for some special tax reliefs.
In
particular:
-
- Small
and medium size companies can deduct 150%, and large companies 125%,
of qualifying revenue expenditure on research and development.
-
-
- The corporate
venturing scheme gives companies tax relief of 20% on the
cost of subscribing for shares in a qualifying unquoted company under
similar conditions to the enterprise investment scheme.
-
-
-
- Tax
relief is given on the cost of intangible assets acquired after 31 March
2002 at the rate of depreciation in the accounts or 4% a year,
whichever is the greater.
Capital gains by
companies
A company's capital
gains are subject to CT at the normal rates with no annual exemption.
-
Companies
continue to receive indexation relief on gains and do not receive
taper relief.
-
Capital
gains may be offset by capital losses of the same accounting period or
capital losses brought forward from previous periods.
-
Roll-over
relief is available where business assets are replaced.
-
Qualifying
disposals of substantial holdings (at least 10%) are exempt. The
vendor and the company being sold must satisfy a trading condition and
the vendor must have owned the shares for at least 12 months.
-
Companies
are subject to different identification rules from individuals for
disposals of shares and securities. Rates of tax
The rate of CT is
fixed for the financial year ending each 31 March. Where an accounting
period straddles this date, the profits are apportioned accordingly.
-
- The main
rate of
CT is 30%. This is charged on the whole of profits where they exceed
£1,500,000, and in all cases for close investment-holding companies.
-
-
- The small
companies rate of 19% is charged on the first £300,000 of profits where
profits are between £50,000 and £1,500,000.
-
-
-
- Profits
between the lower and upper profit thresholds (£300,000-£1,500,000),
are in effect charged at a marginal rate of tax of 32.75%.
-
-
-
-
- Until
31 March 2006, a company with taxable profits up to £50,000 was
charged at 0% on the first £10,000 and an effective marginal rate of
23.75% on the next £40,000. Profits equal to dividends paid in the
period to non-corporate shareholders were charged at 19%. The
remaining profits are charged at the underlying rate. This is the
average rate that would apply if all the profits were taxed at 0% on
the first £10,000 and 23.75% on the next £40,000.
-
-
-
-
-
- Where
a company has associated companies, all the rate thresholds are
divided by the number of associated companies plus one. For example, a
company with three associated companies is taxed at 19% on profits
between £12,500 (£50,000 divided by four) and £75,000 (£300,000
divided by four). Associated companies are broadly companies under
common control.
|
Corporation tax rates
| |
| |
Corporation
tax year
|
2006
|
2005
|
2004
| |
Financial
year
|
to 31.3.07
|
to 31.3.06
|
to 31.3.05
| |
Full
rate
|
30%
|
30%
|
30%
| |
Small
companies rate
|
19%
|
19%
|
19%
| |
|
Small
companies limit
|
£300,000
|
£300,000
|
£300,000
| |
|
Effective
marginal rate
|
32.75%
|
32.75%
|
32.75%
| |
|
Upper
marginal limit
|
£1,500,000
|
£1,500,000
|
£1,500,000
| |
Starting
rate
|
n/a
|
0%
|
0%
| |
|
Starting
rate limit
|
n/a
|
£10,000
|
£10,000
| |
|
Effective
marginal rate
|
n/a
|
23.75%
|
23.75%
| |
|
Upper
marginal limit
|
n/a
|
£50,000
|
£50,000
| |
Minimum
rate on dividends
|
n/a
|
19%
|
19%
| |
|
Company
losses
A company's trading
losses can normally be set against:
-
- Income
and gains of the same accounting period.
-
-
- Income
and gains of the previous year.
-
-
-
- Trading
profits from the same trade in future years.
Losses
of the final 12 months of a trade can be carried back three years. Losses
are set against more recent periods before earlier periods.
Groups of companies
Profits and losses
are calculated separately for each company. However, group relief generally
allows trading losses, losses on property letting, management expenses and
certain other deductions to be surrendered by one company and set against
the profits of other companies in the same group.
In general, 'group' means that 75% of the ordinary share
capital of one company is owned by another company; or several companies
may share the same parent owning at least 75% of the share capital.
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