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HMRC internal manual

Company Taxation Manual

From
HM Revenue & Customs
Updated
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Particular bodies: housing associations: summary of tax treatment

The guidance at CTM40400 onwards concerns housingassociations (CTM40405) that are ‘registered societies’ in Great Britian, formerly industrial and provident societies (see CTM40505 onwards). They are companies for thepurposes of the Taxes Acts and are chargeable to CT on their income and chargeable gains(see CG73100 onwards) subject to such relief as is available under:

 

  • CTA10/S642 - co-operative housing associations (CTM40415 -CTM40445).
  • Section 54 Housing Act 1988 (in Northern Ireland, Article 22, Housing (NI) Order 1992 (SI92/1725(NI15)) tax relief grants (CTM40450 – now essentially defunct).
  • CTA10/PART11/CHAPTER3 - charitable bodies (CTM40460).

A housing association can be a company with investment business within CTA10/S1218B, but it will depend on the particular facts in each case, see [CTM08040](https://www.gov.uk/hmrc-internal-manuals/company-taxation-manual/ctm08040).

As regards management co-operatives, see CTM40465.

As regards self-build societies approved under CTA10/S651, see CTM40470.

Treatment of interest paid

Interest paid is dealt with under the loan relationship provisions.  Relief for interest payable is therefore available as a trade or non-trade debit.  Excess debits may be carried forward and relieved against trading or non-trading credits in the normal way.

CTSA applies to housing associations in the same way as for any other body corporate.