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HMRC internal manual

Company Taxation Manual

Particular bodies: marketing boards

Reserve funds - CTA09/S153

A statutory body which:

  • is concerned with marketing of agricultural products or keeping the price of them stable, and
  • is required under a government approved scheme to pay the whole or part of its trading surplus into a reserve fund,

is allowed a deduction in computing its trading profits for sums it pays into the fund out of its trading profits if the fund satisfies certain conditions. The conditions are set out in CTA09/S154.

Any sums withdrawn by the body from the fund are treated as trading receipts except where they are:

  • paid to a minister or government department, or
  • distributed to producers, or
  • refunded to persons paying any levy or duty.

Payments made to producers out of sums withdrawn from the fund should be taken into account as trading receipts of the recipient.

Any case of doubt or difficulty about the application of CTA09/S153 should be submitted to BAI (Technical) - see ‘Technical Help’ .