National statistics

Background and guidance to interpreting Corporation Tax statistics 2022

Published 22 September 2022

1. Guidance for this publication

This is a National Statistics publication produced by HM Revenue and Customs (HMRC). For more information on National Statistics and governance of statistics produced by public bodies, please visit the UK Statistics Authority website.

The tables in this publication provide breakdowns of Corporation Tax (CT) receipts and liabilities by number of companies, income, deductions, industry sector, financial year, business size and Standard Industrial Classification (SIC) category. All statistics relate to the UK as liabilities and receipts are only reported by companies to HMRC at this level.

1.1 New and updated statistics in this release and methodological improvements

This release includes the CT, Bank Levy and Bank Surcharge receipts figures for the financial year ending 31 March 2022, and the first published CT liability estimates for company accounting periods ending in 1 Apr 2020 to 31 March 2021. Liabilities are gross of company tax credits.

Between the publications released in 2021 and 2022 a review of the methodology and data sources used to produce these statistics was carried out. As a result of this review, and using an improved methodology, there have been some revisions to estimates previously published, particularly on capital allowances. It was determined that annual investment allowance (AIA) was being calculated incorrectly, leading to an overestimate in total capital allowances. This has been corrected in this publication. The error only existed in the 2021 CT publication, and was not present in any other HMRC analyses.

In addition, new analyses have been introduced to help meet user demand. More information on these improvements can be found in the Background Quality Report.

The next scheduled release is in autumn 2023, which will show CT, Bank Levy and Bank Surcharge receipts figures for 2022 to 2023 and CT liabilities for 2021 to 2022.

Forecasts of future CT receipts are produced and published by the Office for Budget Responsibility, and can be found on their website.

1.2 Who might be interested?

These tables are likely to be of interest to policy makers in government, academics, research bodies and journalists. They may also be useful to individuals or organisations interested in the number of taxpayers and tax liabilities in total, and the distributions of numbers and amounts, for example by industrial sector or by size of liability.

1.3 User engagement

We are committed to providing impartial, high quality statistics that meet our users’ needs. We encourage our users to engage with us so that we can improve our official statistics and identify gaps in the statistics that we produce. For more information, please see the Continuous User Engagement Strategy for HMRC statistics.

If you would like to comment on or enquire about these statistics, please use the statistical contacts named at the end of this section.

All HMRC statistics are accessible from the Statistics at HMRC web page.

1.4 UKSA Assessment

These statistics have been assessed for compliance with the Code of Practice for Official Statistics by the UK Statistics Authority (UKSA). The assessment report is available on the UK Statistics Authority website.

1.5 Contact points

• D Pritchard - Receipts
• N Yates - Liabilities
• Email - ct.statistics@hmrc.gov.uk

2. Main points of Corporation Tax

This section explains features of Corporation Tax (CT) that are useful in understanding the statistical tables.

2.1 What is Corporation Tax?

CT is a direct tax charged on the profits made by companies, public corporations and unincorporated associations such as industrial and provident societies, clubs and trade associations. It makes up approximately 9% of the total receipts collected by HMRC.

CT is charged on the profits made in each accounting period, ie the period over which the company draws up its accounts. The rates of taxation are set for the financial year from 1 April to 31 March. Where an accounting period straddles 31 March, and so potentially 2 different tax rates, the company profits are apportioned between the 2 financial years according to the amount of time that the accounting period covers in each financial year. Taxable profits for CT include:

• profits from taxable income such as trading profits or investment profits (except dividend income which is taxed differently)
• capital gains – known as ‘chargeable gains’ for CT purposes

Taxable profits for CT purposes often differ from the pre-tax profits in the company accounts. This is partly because the CT regime has a system of capital allowances, which apply instead of depreciation charges for items such as plant and machinery. There are also other allowances, deductions and reliefs that can be applied when calculating the company’s taxable profits. Particularly significant is group relief; companies belonging to a group can surrender their trading losses to offset against the profits of another group member.

2.2 When do companies report their Corporation Tax liabilities?

When a company submits a Corporation Tax return to HMRC with details of their taxable profits for their year and the amount of tax that needs to be paid, the amount of tax to be paid is known as their ‘liability’. When a company makes a payment to HMRC in relation to their Corporation Tax for any tax year, these are known as ‘receipts’.

Since CT returns are submitted up to 12 months after the end of an accounting period, there is some delay before the estimates on liabilities for a relevant year become available. This analysis includes an estimate of liabilities for the latest financial year, 2020-21, along with revisions for the previous 4 years. The revisions for previous years are normally small but are based on new data received since the previous publication and reflecting any amendments to CT returns reported by companies to HMRC.

In addition, company CT assessments by HMRC are subject to revision and although most assessments are finalised within 2 years, there are exceptional cases that can take much longer. There is, therefore, no specific point at which all the CT liabilities for a particular year can be considered as ‘final’.

2.3 Profits and deductions

For CT purposes, a company’s profits comprise its income and capital gains. Income, whether from trading or investments, is calculated in the same way as for income tax purposes including capital allowances where appropriate. Gains are calculated in the same way as for capital gains tax except that companies have no exempt amount and company gains are not affected by the reforms made in 1998 to capital gains tax.

Capital allowances provide relief, for CT purposes, for the consumption or depreciation of capital assets incurred for the purposes of carrying on a trade. Different types of assets qualify for different rates of allowances.

Capital allowances may be claimed in the year in which they accrue, any unused capital allowances may be carried forward to set against profits in later years. They may also be carried back in the same way as trading losses. Tax credits were introduced in the 1999 Budget, and extended later, to provide enhanced relief for research and development and some other types of expenditure. For some types of expenditure, non-taxpayers can receive a payable tax credit.

A company that makes a trading loss may carry that loss back for one year to set against the profits of an earlier accounting period. Temporary legislation introduced in response to coronavirus (COVID-19), allows companies to carry back losses arising in financial year 2020 to 2021 and 2021 to 2022 by up to 3 years, instead of one.

An unrelieved trading loss can also be carried forward without time limit to set against income from the same trade in a future accounting period.

For profits arising after 1 April 2017, loss restriction limits the amount of brought forward loss that can be used to reduce profits for companies or groups with profits of over £5 million.

Deductions are allowed from a company’s total profits for any charges (interest and other payments) it pays and, in the case of an investment company, its management expenses. Since April 1996, “loan relationship” rules have been in force for the treatment of interest and similar payments. A deduction against the tax liability is allowed for income tax deducted at source from interest received (to the extent that it is not used to cover income tax the company itself deducts on interest payments it makes). Double taxation relief for foreign tax is allowed as a deduction against the tax charged on profits.

2.4 Company groups

Certain rules and reliefs apply to companies that operate as a group. A group typically consists of a parent company and a number of subsidiary companies. For 2 companies to be considered members of the same group for tax purposes, one company has to have at least 75% ownership of the other, or they must both be owned (at least 75%) by a third company. A company that makes a trading loss can surrender that loss as group relief to set against the profits of an equivalent accounting period of another group member. Assets can be transferred between group members without giving rise to a chargeable gain at the time of transfer.

2.5 Tax rates

From 1 April 2015, there has been a unified rate of CT rather than separate main and small profits rates. From 1 April 2017 the rate has been set at 19%.

There was a lower rate of CT for companies with small profits, known as the small profits rate (SPR), formerly the small companies’ rate (SCR). This rate applies when the profits are below a lower limit. Between that limit and an upper limit, the company is taxed at the main rate, but most companies can claim marginal relief to give a smooth progression in the average tax rate from the lower rate to the main rate. Above the upper limit, the main rate applies. The profit limits are restricted for companies associated with one or more other companies according to the number of associated companies to prevent abuse by a company fragmenting into smaller ones.

Different tax rates apply to companies with income and gains from oil and gas and gas extraction or oil rights, known as ‘ring-fence’ companies. These companies are also subject to a Supplementary tax charge on their ring-fenced profits. More information about ring-fence companies and CT statistics can be found on GOV.UK.

2.6 Payment and assessment arrangements

Companies are required to assess their own CT liabilities on broadly the same principles that underlie income tax self-assessment. However, unlike income tax, the deadline for paying CT is before the deadline for filing the company tax return. The company tax return has to be filed within 12 months after the end of the accounting period.

Companies with taxable profits of more than £1.5 million annually are normally required to pay by Quarterly Instalment Payments (QIPs), where the first instalment becomes due in month 7 of the accounting period. Smaller companies in a group where the total taxable profits across the group are over £1.5 million must also pay under the QIPs system. Groups can set up Group Payment Arrangements whereby one nominated company makes instalment payments on behalf of the group. Smaller companies outside the QIPs regime have to pay CT within 9 months and a day of their accounting period end date.

From the 1 April 2019, a new payment regime has been introduced for ‘very large’ companies which requires their CT payment to be paid 4 months earlier than previously. A very large company is one whose profits for the accounting period in question are at an annual rate of more than £20 million. More information about this new regime can be found on the information for very large companies section of the GOV.UK website.

From 1 April 2011, companies have to submit their tax returns to HMRC online for accounting periods ending after 31 March 2010. Tax computations and (with a few exceptions) company accounts must be submitted in Inline eXtensible Business Reporting Language (iXBRL) format. CT must also be paid electronically.

2.7 Historical Background

Corporation Tax rates have changed since its introduction in 1965. The table below provides a timeline of these changes.

Date	Corporation Tax changes
1965	CT introduced, with a uniform rate on all profits. An additional charge to income tax was made when profits were distributed.
1973	Small Companies’ Rate (SCR) introduced, with Marginal Relief to smooth the progression between the SCR and the Main Rate.
1973	Advance Corporation Tax (ACT) and tax credits (the “partial imputation system”) introduced.
1980s	Substantial reductions in the Main Rate (from 52% to 35%) and the SCR (from 40% to 25%).
1980s	Reforms to the capital allowances regime.
1990s	Continued reductions in the Main Rate (from 35% to 30%) and the SCR (from 25% to 20%).
October 1993	CT Pay and File system introduced.
2 July 1997	Tax credits on dividends abolished.
1999	ACT abolished.
1999	CT Self-Assessment introduced.
1999	Quarterly instalment payments (QIPs) introduced for large companies.
1 April 2000	Starting Rate of 10% introduced.
1 April 2002	Starting Rate cut to zero.
1 April 2002	SCR reduced from 20% to 19%.
1 April 2004	Non-Corporate Distributions Rate (NCDR) introduced on profits distributed to “persons who are not companies”.
1 April 2006	Starting Rate and NCDR replaced by a single rate set at the SCR.
1 April 2007	SCR raised from 19% to 20%.
1 April 2008	Main Rate reduced from 30% to 28%.
1 April 2008	SCR raised from 20% to 21%
1 April 2011	Main Rate reduced from 28% to 26%.
1 April 2011	Small Profits Rate (SPR), formerly known as SCR, reduced from 21% to 20%.
1 April 2011	Introduction of compulsory online filing for Company Tax returns
1 April 2012	Main Rate reduced from 26% to 24%
1 April 2013	Main Rate reduced from 24% to 23%
1 April 2014	Main Rate reduced from 23% to 21%
1 April 2015	Single unified rate of 20% introduced.
1 April 2017	Single unified rate reduced from 20% to 19%

2.8 The Bank Levy

The Bank Levy is an annual charge based on the equity and liabilities reported in year-end balance sheets, for periods of account ending on or after 1 January 2011. The Bank Levy applies to the following:

• UK banks, banking groups and building societies
• Foreign banking groups operating in the UK through permanent establishments or subsidiaries
• UK banks and banking sub-groups in non-banking groups

No charge arises on the first £20 billion of chargeable equity and liabilities of the relevant period, which in practice means that only banks with a large operating presence in the UK pay the Bank Levy.

The Bank Levy is returned to HMRC as part of the supplementary pages to the CT600 company tax return. Liabilities and receipts are recorded on the HMRC COTAX system. All companies subject to the Bank Levy are deemed to be ‘large companies’ for payment purposes and therefore all liabilities are paid as quarterly instalments under the same provisions as CT.

Bank Levy liabilities are excluded from the CT liabilities in this publication.

2.9 The Bank Surcharge

The Bank CT Surcharge, commonly known as the Bank Surcharge, was introduced in The Finance Act (No 2) 2015 to levy a surcharge on the profits of banking companies. From 1 January 2016, Bank surcharge was introduced at a single rate of 8% on chargeable profits over £25 million.

The Bank Surcharge applies to all banking companies and building societies within the scope of the charge to UK CT. The surcharge profits are calculated on the same basis as for CT but before the offset of losses that arise before the commencement date or from non-banking companies, and before the surrender of group relief from non-banking companies. R&D expenditure credits are excluded from the surcharge. The surcharge also applies to any chargeable profits of a Controlled Foreign Company (CFC) which are apportioned to a banking company.

The Bank Surcharge is paid alongside a company’s liability to CT. Liabilities and receipts are recorded on the HMRC COTAX system.

HMRC Official Statistics on CT and PAYE receipts from the banking sector is available on GOV.UK.

3. Data Sources and methodology

This section explains some key features of CT that are useful in understanding the statistical tables. More information about the data and the quality assurance process can be found in the Background Quality Report.

3.1 Data sources

Receipts

The data for CT receipts and Bank Levy receipts comes mainly from postings recorded on the HMRC COTAX administrative system. These are downloaded every night into databases for analysis the following day.

Receipts figures are subject to ongoing quality assurance and daily scrutiny as part of the HMRC role in monitoring the public sector finances.

Liabilities

The data for CT liabilities comes from CT assessments and returns as recorded on the HMRC COTAX administrative system.

The available data for each company is as recorded on the Company Tax Return (CT600) form, including any modifications or additions made in subsequent assessments. The CT600 form contains a systematic record of the company’s CT calculations, starting with its income and chargeable gains and considering any relevant deductions and reliefs.

A large company may trade at many different locations throughout the UK. However, its CT return will be made on behalf of the whole company and linked to its registered office address. A geographical breakdown would show all of the company’s profits and tax liability as originating at the location of the registered office, which does not reflect the company’s actual business activities. Therefore, CT National Statistics are only produced at national level. Statistics showing sub-national breakdowns of tax receipts can be found at the Country and regional public sector finances page of the ONS.

Tables include breakdowns by industrial sectors and divisions, eg ‘Agriculture, Forestry and Fishing’ and the classification is based on the UK Standard Industrial Classification (SIC) 2007. Companies do not report their SIC 2007 sector to HMRC as part of their CT return or registration so they have been assigned to a sector based on data from external sources; this is predominantly matching records to Companies House Free Data Product and the Office for National Statistics’ (ONS) Inter-Departmental Business Register (IDBR) survey. Some categories have been combined in order to protect taxpayer confidentiality.

Further information about Companies House data products can be found on GOV.UK, and on the IDBR from the Inter-Departmental Business Register page of the ONS website.

Further information about industrial classification by the ONS and by Companies House can be found at the following links:

• the current Standard Industrial Classification (SIC) that’s located on the Office for National Statistics website
• a condensed list of SIC codes on GOV.UK, for providing Companies House with a description of your company’s nature of business.

3.2 Methodology

CT returns are allocated to financial years according to the end date of the accounting period. CT returns are normally due 12 months after the end of an accounting period, and then it takes a further period to capture the data electronically. Allowing for this and late returns, there is some delay before the estimates for a relevant year become available. In this current release, the most recent available estimates for liabilities relate to tax year 2020 to 2021.

CT assessments are subject to revision and although the majority of assessments are finalised within 2 years, there are exceptional cases which can take much longer. Therefore, there is not a specific point when all the CT liabilities for a particular year can be considered as ‘final’.

The statistics are revised each year for the 5 years before the latest published year. Reasons for changes in liabilities include:

• revisions to the assessment, for example to carry back losses from later years, or because of an HMRC enquiry
• amendments to correct errors in the original assessment
• late submission of the company’s tax return

The total CT liability typically decreases from the time of initial publication to the revision in the following year’s publication. Changes in recent years have been up to 2% per year in either direction. These changes were observed in the statistics in recent years. It should not be assumed that the same pattern of changes will apply in future.

3.3 Potential sources of error

For more information regarding the potential sources of error please consult the Background Quality Report.

4. Guidance on specific tables

Table 1

The main points that are useful to understand table 1 are:

• that receipts are gross of company tax credits, information on company tax credits can be found in HMRC’s monthly receipts statistics
• for Onshore CT, the category of ‘Other industrial and commercial’ includes overseas companies
• offshore CT quarterly instalments and balancing payments include the supplementary charge in respect of ring fence trades. These values can be found on the Statistics of government revenues from UK oil and gas production webpage of GOV.UK

Table 2

The main points that are useful to understand table 2 are that:

• it is organised to follow the main stages of the CT600 form leading to a company’s calculation of their self-assessment of tax payable before restitution tax
• the ‘Income’ section includes all taxable income
• ‘Other taxable income’ includes all sources of taxable income excluding trading profits and gross chargeable gains
• ‘Trading losses arising in-year’ is not the amount of losses that companies are using to reduce their profits, but rather the total amount of losses of trades carried on wholly or partly in the UK or wholly outside the UK, that occurred during the financial year
• the ‘Deductions’ section includes all deductions and reliefs prior to the calculation of a company’s profits chargeable to CT
• ‘In-year and brought forward losses claimed against profits’ is the sum of all CT600 boxes relating to these types of losses, that companies have used to reduce taxable income
• ‘Carried back losses claimed against profits’ are trading losses that have been carried back from a future financial year and used to reduce taxable income
• the total estimate of carried back losses claimed against profits is not shown for the latest financial year, as the data is incomplete due to the timing of when returns and amendments are submitted to HMRC
• ‘Group relief including carried forward group relief’ is the sum of all group relief claimed
• ‘Other deductions’ includes all other deductions available to companies, in their calculation of profits chargeable to CT, including losses on unquoted shares and capital allowances for the purposes of management of the business for investment companies
• the ‘Tax charge’ section includes some key sub-totals, further deductions and reliefs, and tax outstanding or overpaid
• ‘Profits chargeable to Corporation Tax’ is the total taxable income minus total deductions, and is the amount upon which the relevant CT rates will be charged
• ‘Corporation Tax chargeable’ is the amount of tax required to be paid, based on the rate(s) of tax for the period of the return
• ‘Other reliefs, tax outstanding or overpaid’ includes all other reliefs, deductions or additions applied to the Corporation Tax chargeable amount before arriving at the self-assessment of tax payable before restitution tax
• examples of ‘Other reliefs, tax outstanding or overpaid’ include Income Tax deducted from gross income included in profits, Controlled Foreign Companies tax payable and Supplementary charge of ring fence trades
• ‘Corporation Tax payable’ is the total of all self-assessment of tax payable before restitution tax

Table 3

The main points to understand table 3 are that:

• it is organised in the same manner as table 2, following the main stages of the tax calculation
• each table applies to a different broad industry sector
• some information has been removed to protect taxpayer confidentiality
• additional information is presented in the ‘Ring fenced oil and gas companies’ table specific to this industry’s companies eg ring fence profits and supplementary charge

Tables 4 and 5

The main points to understand tables 4 and 5 are that:

• they are presenting much of the same information as in tables 2 and 3, but split by Standard Industrial Classification (SIC) section, and for a single financial year
• ‘Capital allowances included in profits and losses’ is the total amount of capital allowances minus balancing charges and disposal values, that companies have included in their profits and losses calculations

Tables 6 to 8

The main points that are useful to understand tables 6 to 8 are that:

• all 3 tables are based on companies self-declared SIC 2007 code that reflects the main business activity of the company
• to preserve taxpayer confidentiality some categories have been combined
• table 6 analyses CT liabilities by SIC section, the top level of SIC hierarchy, and financial year
• tables 7 and 8 present CT liabilities at the more granular level of SIC division, by financial year

Table 9

The main points that are useful to understand table 9 are that:

• data is being grouped into bands of how much an individual taxpayer was liable to pay
• table 9A presents the total amount of CT liability that falls into each band eg a total of £3 million of CT liabilities was contributed by companies that had an individual CT liability of between £0 and £100
• table 9B presents that same data but by the number of companies that fall into each band

Table 10

The main points that are useful to understand table 10 are that:

• it presents CT liabilities by estimated small and medium-sized enterprise (SME) status
• the criteria used to determine a company’s SME status are employees, assets and turnover
• the criteria is considered at group level and as defined by the Companies Act definition of SME
• there are 3 categories that qualify as a SME: ‘Micro’, ‘Small’ and ‘Medium’
• if a company does not meet the requirements to be considered a SME, it is classified as ‘Large’
• not all of the information required to estimate a company’s SME status is collected by HMRC as part of CT returns and registrations, and so external data is also used
• there are a significant number of companies with insufficient data to make an accurate estimate, these are classified as ‘Unknown’
• ‘Unknown’ SME status companies are more likely to be ‘Micro’ or ‘Small’ due to lesser requirements on these companies to submit detailed information to Companies House

Table 11

The main points that are useful to understand table 11 are that:

• these figures on Capital Allowances have been revised significantly since the previous publication, as described in section 1.1
• table 11A includes the total amount of capital allowances minus balancing charges or disposal values, for each type of capital allowance that can be claimed
• Annual Investment Allowance is reported separate to the total value of capital allowances claims, to prevent double counting; it can also be included in one or both of the Machinery and Plant allowances
• some cells in the table are empty to indicate that the allowance, or the relevant box on the CT600, was not available in that year
• table 11B includes the number of companies who have recorded either a capital allowance claim, balancing charge, or disposal value within each type of capital allowance
• the ‘Total claiming any capital allowances or recording balancing charges’ is not a sum of the rows above, as companies may claim more than one type of capital allowance

Table 12

The main points that are useful to understand table 12 are that:

• data is being grouped into bands in a similar way to table 9
• the bands in table 12 are the amounts of capital allowances minus balancing charges or disposal values eg a total of £1 million of capital allowances claims was contributed by companies that had an individual capital allowances claim of between £0 and £100
• it is possible for companies to record higher balancing charges than their capital allowances claim; the negative difference is added onto their profits total, rather than being deducted from it and is represented by the ‘less than £0’ band in the table