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HMRC internal manual

Company Taxation Manual

Corporation Tax: management expenses: company status - liquidation

A liquidator’s main objective is to realise a company’s assets and wind up its affairs. It is not to make a profit by continuing to hold investments and is therefore unlikely to have an investment business. Indeed it is unlikely to have any business at all. It is therefore most unlikely that a company in liquidation will satisfy the requirements of CTA09/S1218B. However, in exceptional circumstances, it may be possible for a company in liquidation to be ‘a company with investment business’.

If you have a case where it is contended that a company has or continues to have a business which consists in the making of investments after the commencement of winding-up, you should submit the papers to BAI (CT Structure).