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HMRC internal manual

Company Taxation Manual

Corporation Tax: introduction: application of IT exemptions

ICTA88/S9 (4)

Provisions of the IT Acts which gave exemption from IT had, prior to Tax Law Rewrite, the same effect for CT, provided this was consistent with the CT Acts. So a company which was exempt from IT on its income because it is a charity was also exempt from CT on its income.

Tax Law Rewrite introduced a different approach, treating corporation tax as a separate code. Income tax principles are no longer applied for CT purposes. There are specific provisions which link a company’s income from holding an office to ITEPA03 provisions (CTA09/S969 (4)).