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HMRC internal manual

Company Taxation Manual

From
HM Revenue & Customs
Updated
, see all updates

Distributions: general: LEAs, LECs & TECs

CTA09/S82 provides tax relief for contributions made to LEAs, LECs and TECs - seeBIM47610.

A company owned by:

  • a Local Enterprise Agency (LEA), or
  • a Local Enterprise Company (LEC), or
  • a Training and Enterprise Council (TEC),

may make contributions to its parent which may be treated as distributions.

CTA09/S82 provides tax relief for contributions made to LEAs, LECs and TECs (BIM47610).

For contributions made before 17 July 2012, CTA/S1002 and S1021 prevented distribution treatment applying where

  • a company is a 51% subsidiary of an LEA, LEC or TEC, and
  • the LEA, LEC or TEC and the company are bodies corporate, and
  • the company makes contributions to the LEA, LEC or TEC.

This prevention did not however apply where the LEA, LEC or TEC was not a body corporate. For contributions made on or after 17 July 2012, CTA10/S1002 and S1021 are repealed and contributions by the company to the LEA, LEC or TEC may give rise to distributions in all cases.