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HMRC internal manual

Company Taxation Manual

Corporation Tax: management expenses: employees seconded to charities

CTA09/S1235

A ‘company with investment business’ may make available the services of an employee to a charity (or to certain educational establishments) on a temporary basis. In such a case the expenditure on the remuneration and related costs of the employee may still qualify as an expense of management. There is relief under CTA09/S1235 for expenditure attributable to the employment. There is guidance on employees seconded to charities at BIM47115 and to educational establishments at BIM47120.