Beta This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

Company Taxation Manual

Particular bodies: retirement benefits schemes

Any profits accruing to a corporate trustee of a retirement benefits scheme, whether registered or not, would accrue to the company in a fiduciary capacity. CTA09/S3 (2) provides the profits are not within the charge to CT. But IT and CGT would be chargeable on any income or chargeable gains that are not exempt.

Refer any claim that a retirement benefits scheme, or its trustees, should be liable for CT to Pension Scheme Services.

ITA07/S946 (collection of income tax from companies) does not apply to payments made or income received if it is held in trust. If the trustee of a retirement benefits scheme is a limited company, the payments which the company makes out of the trust fund in its capacity as trustee, and the taxed income it receives, are dealt with in the usual way for IT and are excluded from the machinery of ITA07/PART15/CHAPTER15.

CTM60290 explains how to decide whether a company is close if its shares are held by the trustees of a registered pension scheme.