For the purpose of the small profits relief in CTA10/PART3 the augmented profits of a company for any accounting period are defined by CTA10/S32 as:

the taxable total profits of that period, as defined in CTA10/S4 (2) and (3), plus

any franked investment income received by the company in that period other than franked investment income which the company (if a member of a group) receives from companies within the group.

For this purpose, franked investment income is treated as received from within the group only if the dividends are

paid by a 51 per cent subsidiary of the recipient or of a company of which the receiving company is a 51 per cent subsidiary, or

Want to read more?

This content requires a Croner-i Tax and Accounting subscription.

Existing subscriber? Log in

No subscription?

Contact us to discuss your requirements.