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HMRC internal manual

International Manual

HM Revenue & Customs
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Arbitrage: legislation and principles - deductions: condition B - deduction for corporation tax

The deductions rules apply if and only if all of the four conditions A-D set out in s233 TIOPA 2010 are met.

Condition B is that the company must be in a position to claim or must have claimed a corporation tax deduction in respect of the transaction to which Condition A applies, or be in a position to set off or have set off against profits in an accounting period an amount relating to the transaction. S233(3) TIOPA 2010.