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HMRC internal manual

Company Taxation Manual

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HM Revenue & Customs
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Corporation Tax: management expenses: timing of deduction of emoluments

FA89/S44 (1) provides that in calculating the CT profits of an investment company (or a ‘company with investment business’ for periods starting on or after 1 April 2004) for accounting periods ending after 5 April 1989, no deduction is to be made for emoluments:

  • which would otherwise be deducted apart from FA89/S44, and
  • which are not paid within nine months of the end of the period of account.

Instead these emoluments are to be deducted in the computation of the CT profits of the accounting period in which the emoluments are paid.

Follow the guidance on this in BIM47130 onwards. You have to modify this guidance for an investment company, or a ‘company with investment business’, by reading the statutory references to FA89/S43 as applying the equivalent subsections of FA89/S44.