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HMRC internal manual

Company Taxation Manual

Corporation Tax: computation of income: provisions common to IT and CT

ICTA88/S9 (5) (which was unaffected by Tax Law Rewrite) ensures that any provision of the IT Acts applied to CT will work properly in a case where it has to apply to both. Where provisions of the IT Acts apply to both taxes, the two taxes are, as far as possible, to be treated as if they were one tax. So any provision regulating the effect of a transaction between two individuals also governs a similar transaction between an individual and a company. The provision governs:

  • the IT of both the individuals, and
  • the IT of the individual and the CT of the company.