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HMRC internal manual

Company Taxation Manual

Corporation Tax: management expenses: timing of relief - periods from 1 April 2004

 CTA09/S1224

FA04 changed the timing of relief for expenses of management.  For accounting periods up to 31 March 2004, relief was only available for expenses which had been ‘disbursed for’ the accounting period.  Broadly it meant that the expenses must *actually *be paid out,

For periods starting on or after 1 April 2004, expenses are eligible for relief in the periods to which they are referable.  The period to which an expense is referable is defined CTA09/S1224.

The change from the disbursed (paid) basis for relief has also meant the introduction of a rule reversing a deduction where, for example, a provision is reversed.  In some instances the rule will create a Case VI charge.  Further details on therules are in CTM08570.

Broadly, the timing rule now follows the accountancy treatment, so that the expenses are deductible in the accounting period in which they are debited (defined at CTA09/S1255) in a company’s accounts, provided that those accounts are drawn up in accordance with GAAP.  This rule is subject to any specific statutory timing rules for particular types of expenditure, e.g. CTA09/S1249.

Where the company’s accounts for a period of account coincide with an accounting period, then expenses debited in those accounts are referable to that accounting period.

Where a period of account does not coincide with an accounting period, for example where the company draws up accounts for a period of account of more than 12 months, then CTA09/S1225 (2) and (3) apply.  In such a case the expenses are apportioned between the periods on a time apportionment basis unless that would give an unreasonable or unjust result, in which case a just and reasonable method is to be used.

Expenses may have been brought into account for a period of account but the accounts may not be drawn up in accordance with GAAP, for example in the case of a company established in a country where GAAP is not applied.  In these circumstances the expenses of management are referable to an accounting period to the extent that they would have been referable to that period if the accounts had been drawn up in accordance with GAAP (CTA09/S1226).

Where there is an accounting period but no accounts are drawn up for the company then the amounts referable to that accounting period are those that would have been referable, assuming a period of account coinciding with the accounting period, and the expenses would have been allowed in those accounts in accordance with GAAP if accounts had been drawn up (CTA09/S1227).