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HMRC internal manual

Company Taxation Manual

Corporation Tax: management expenses: timing of deduction of emoluments

 CTA09/S1249 and S1250

CTA09/S1249 provides that  in calculating the CT profits of a ’company with investment business’ no deduction is to be made for employees remuneration:

  • which would otherwise be deductible under CTA09/S1219 and
  • which are not paid within nine months of the end of the period of account.

Instead the remuneration is 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, reading the statutory references to CTA09/S1288 and S1289 as applying CTA09/S1249 and S1250.