CTM03640 - Corporation Tax: small companies: accounting period straddling financial year: differing relevant amounts or limits

Where an accounting period straddles the beginning of a financial year for which the first and second relevant amounts or the lower and upper relevant maximum amounts as in CTM03510 and CTM03520 differ from those of the preceding financial year, the two parts of the accounting period are treated for the purposes of the CT starting rate or small companies' relief as if they were separate accounting periods. The profits ( CTM03600) are apportioned between those parts on a time basis (ICTA88/S834 (4)). The profits for each part are then compared with the appropriate proportions of the relevant amounts for the financial year in which each part falls.

If the profits in either part fall between the appropriate proportions of the first and second relevant amounts or the lower and upper relevant maximum amounts, it is necessary to apportion the basic profits ( CTM03505) on a time basis and to compute marginal relief as if each part is a separate accounting period. Authority for apportionment is given by the Finance Act for the year in which the amounts change.

The parts are also to be treated separately in restricting the limits to take account of associated companies ( CTM03570 and CTM03580). The limits for one part are not to be reduced in respect of a company that is associated only during the other part.

For any accounting period straddling 1 April 2000 (when the CT starting rate was introduced), FA99/S28 (7) gives authority to treat the two parts of the straddling accounting period as if they were two separate accounting periods for the purposes of ICTA88/S13AA. Where there is a claim under ICTA88/S13AA in relation to the part of the accounting period beginning with 1 April 2000, the straddling period will be treated as two separate accounting periods for the purposes of ICTA88/S13 as well.

If the fraction or rate changes, but the relevant amounts remain unchanged, apportionment of the amount computed under Section 13 (2) or Section 13AA (2) ( CTM03540) is required so that the different fractions or rates can be applied (see CTM03653). This apportionment does not mean that the two parts are to be considered separately in restricting the limits to take account of associated companies.