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HMRC internal manual

Company Taxation Manual

Introduction: concerns within the charge to CT

CT is charged on the profits of companies (see CTM00510).

An unincorporated association will normally fall within the definition of a company - see CTM00510. The term ‘unincorporated association’ includes members’ clubs (CTM40105) and trade associations (CTM41200+).

In general, trustees do not come within the phrase ‘unincorporated associations’. Guidance on the trustees of an unauthorised unit trust is at SAIM6050.

Authorised unit trusts within CTA10/S616 to S619, formerly ICTA88/S468, are included in the charge to CT, but are subject to special rules (see CTM48200+).

For guidance on the treatment for tax purposes of particular bodies see CTM40000+.


Sometimes the directors and shareholders of a small company will decide that incorporated form is no longer the appropriate vehicle for carrying on a trade.

Disincorporation Relief was introduced from 1 April 2013 and is a form of roll-over or deferral relief. It allows a company to transfer certain assets to shareholders who continue the business in an unincorporated form, without the company incurring a Corporation Tax charge on the disposal of those assets by the company. It is available for transfers made between 1 April 2013 and 31 March 2018. See CG58000 onwards and CIRD43000 onwards.