CTM92790 - Corporation Tax self-assessment (CTSA): quarterly instalments: anti-avoidance - exemptions
There are exemptions as below.
With reference to a change in the start or end date of a relevant period
- accounting period changes caused by decisions made or facts in existence prior to 25 November 1997,
- accounting period changes caused by an event in ICTA88/S12 (3)(c) to (e) (cessation of a trade for example) except when the event is caused by reason of the transfer of the company's activities to a fellow group company,
and
- accounting period changes caused by certain action taken to align the company's accounting period with that of a new ultimate parent company.
With reference to a company entering into any arrangements to transfer some of its taxable profits to another company in the same group
- transfers of taxable profits where the transferee company has the same accounting period as the transferor, and the case is not one where the transferor has changed its accounting date, or
- where the profits of the transferor are reduced by £5 million or less, or a proportionate amount for a period of less than twelve months.
