Abortive expenditure

Accounting basis

Connected companies

Departures from generally accepted accounting practice

Accounting for credits and debits

Adjustments on change of basis

Amortised cost basis

Amounts not fully recognised for accounting purposes

Basis of accounting

Capital expenditure

Cessation of loan relationship

Change of carrying value

Companies without GAAP-compliant accounts


Equity or shareholders' funds

Fair value

Fair value accounting

Imported losses


Opening and closing values

Release of debts

Revaluation of assets

Reversal of disallowed debits

Rules differing from generally accepted accounting practice

Writing-off government investments

Accounting methods

Amounts recognised in determining company's profit or loss

Change in accounting standards

Change of accounting basis applicable to assets or liabilities

Connected parties

Deferment of transitional adjustments

Fair value accounting

Accrual of purchase discount on loan repayable on demand

Alternative finance arrangements


Amendments of Parts 5 and 6 of CTA 2009

Amounts taxed under rules

Anti-avoidance provisions

Double charge, avoidance of

Mandatory convertibles

Repo and stock lending arrangements

Application of Finance Act 1996, Sch. 9, para. 13 to debit arising under FA 1996, Sch. 9, para. 19A

Assignment of contingent third-party debt claims

Assignment of right to interest under the loan to another group company

Associated companies

Authorised investment funds

Authorised investment trusts

Authorised unit trusts

Bad debts/impairment

Connected party situations

Consortium relief


Writing-off government investment

Bad or doubtful debts

Relieved before commencement

Bringing amounts into account, trading/non-trading

Building societies

Calculation of profits and deficits

Capital expenditure, debits and credits treated as relating to

Ceasing to be party to

Ceasing to be resident in UK

Ceasing to be UK resident

Change of accounting practice

Charge to tax

As income

Non-trading profits

Chargeable assets held after commencement, transitional provisions

Chargeable gains

Collective investment schemes

General savings


Qualifying corporate bonds

Traders and their guarantors

Charitable companies, exemption for non-trading profits

Civil proceedings for recovery of property


Carry-back of non-trading deficits

Carry-forward as non-trading debit of next accounting period

Carry-forward of deficit to next accounting period

Group relief

Sideways relief

Claims for relief

Close companies

Deeply discounted securities

Loans to participators

Collective investment scheme

Commencement and transitional provisions

Anti-avoidance provisions etc


Sections 321, 349 and 605 of CTA 2009

Straddling accounting periods treated as split for certain purposes

Transitional adjustments relating to derivative contracts

Transitional provision relating to abolition of 'fairly represents' test

Transitional provision relating to fixed capital asset or project

Commercial rate of interest

Company is not, or has ceased to be, party to loan relationship

Company migrations

Company with investment business, restrictions on relief

Carry forward of non-trading deficit

Debits to be brought into account

Connected companies

Amortised cost basis, application

Beginning to be connected

Ceasing to be connected

Close company loans to participators

Corporate rescue exception

Debt-for-debt exception

Deemed debt releases on impaired debts

Deeply discounted securities

Equity-for-debt exception

Exclusion of credits on release or reversal of impairments

Exclusion of debits for impaired or released debts


Late interest


Occupational pension schemes, trustees

Related transactions, disregard of

Connected party situations

Impairment debts and impairment losses

Consortium relief, bad debts/impairment

Contracts for financial futures, transactions by insurance companies

Controlled foreign companies

Convertible securities

Corporation tax

Counteracting effect of avoidance arrangements

Credit unions

Creditor relationship, meaning

Credits and debits brought into account

Accounting bases

Adjustments on change of accounting basis

Amounts recognised in determining profit or loss

Companies without GAAP-compliant accounts

Disregard of pre-2005 disallowed debits

General principles


Overseas sovereign debts

Reversal of debits, restriction

Rules differing from generally accepted accounting practice

Cross-border transfers of business and mergers

DCC holdings

De-recognised for accounting purposes

Debit not arising from derivative contract

Debit not reflecting fair representation of loss from transactions

Debit relating to 'tracker shares' linked to in the money swap receipts

Debit representing cost of shares in respect of loan relationship with a subsidiary

Debits and credits brought into account

Debits and credits brought into account, creditor in liquidation

Debt capping rules, worldwide groups

Debtor relationship, meaning

Deductible debit

Deduction of tax at source

Deep discount securities

Deep gain securities


Qualifying indexed securities

Deeply discounted securities

Accounting periods pre-1 April 2007

Close companies

Connected companies


Persons indirectly standing in position of creditor

Pre-1 October 2002


Derivative contracts


Connected debtor and creditor, debits exceeding credits

Embedded derivatives

Discounted securities

– see also Discounted securities

Chargeable gains

Disguised interest

Excluded shares

Exclusion where arrangement has no tax avoidance motive

Exclusion where return otherwise taxable


Regarded as profit from

Shares accounted for as liabilities

Disguised interest rules

Controlled foreign companies

Disposals for consideration not fully recognised

Disregard of foreign tax referable to interest under


Repos, exception for

Stock lending, exception for

Effect of assignment on recognition of loan in accounts of assignor company

Embedded derivatives

Embedded rights and liabilities to financial or equity instruments

European company (SE)

European cross-border mergers

European cross-border transfers of business

Exchange gains and losses

Expenses incurred

Fair representation of profits

Financing costs and income

Financing costs and income of group companies

Floating rate securities

Foreign exchange gains and losses

Funding bonds

GAAP-compliant accounting treatment


Gilt-edged securities

– see also Gilt-edged securities

Group mismatch schemes

Controlled foreign companies

Economic profits and losses, meaning

Finance arrangements

Foreign companies and foreign permanent establishments


Group, meaning

Losses and profits to be disregarded


Provisions treated as of no effect

Relevant tax advantage, meaning

Repos or quasi-repos

Scheme group, meaning

Scheme loss, meaning

Scheme period, meaning

Scheme profit, meaning

Scheme, meaning

Tax capacity assumption

Trading income

Group of companies, novation of liabilities

Group relief

Bad debts/impairment


Group relief, impaired or released consortium debts

Accounting periods

Carry forward of claims where no net consortium debits

Credit for release brought into account on amortised cost basis



Reduction of claims where earlier net consortium debits

Reduction of credits exceeding impairment losses

Reduction of loss debits


Intra-group transactions

Groups of companies, restriction of deduction for financing costs and income

Groups of companies, transfers between

Fair value accounting


Notional carrying value

Transferee leaving group

Imported losses

Imputed interest

Industrial assurance business

Insolvency, corporate rescue etc

Insurance companies

Basic life assurance and general annuity business


I - E basis

Loss relief

Inter-company transactions, deductions

Interest coupons recognised in accounts during repo term

Interest on overpaid/underpaid tax

Interest relief

Interest under, meaning

Interpretation of section 455B

Interpretation of section 698B

Intra group forward subscription agreement

Investment companies functional currency

Investment life insurance contracts

Investment life insurance contracts, gains on

Investment trusts

Creditor relationships, accounting methods


Judgments, interest on

Late interest rules

Deduction of tax

Legal and accounting concepts

Life insurance contracts, gains on

Limits on/reduction of credit for foreign tax

Current year's non-trading deficits

Deductions, allocation of

Earlier years' non-trading deficits


Non-trading debits

Lloyd's underwriters

Loss restrictions

Mandatory convertibles

Manufactured dividends and interest


Overseas securities

Manufactured interest

Matched, meaning

Matters in respect of which amounts are to be brought into account

Matters treated as



Money debt, meaning

Money debts


Exchange gains and losses

Impairment losses

Imputed interest on transfer pricing adjustments

Interest on judgments

Interest on tax


Non-lending relationships

No profit recognised in accounts

Non-lending relationships

Amounts to be brought into account

Discounts on disposals pre-22 March 2006

Exchange gains and losses treated as money debts



Interest, meaning

Involving discounts

Money debt, meaning

Not involving discounts

Relevant matters

Non-trading deficits

Brought into account



Set off deficit against profits of deficit period

Non-trading deficits, relief

Non-trading profits


Carry forward of unrelieved deficit

Charge to tax

Non-UK resident ceasing to hold loan relationship for permanent establishment

Notional closing values of relevant assets

Notional interest

Offshore funds

Oil extraction activities, calculation of profits

Open-ended investment companies



Order of giving relief

Overpaid/underpaid tax, interest on



Involving companies

Structured finance arrangements

Partnerships involving companies

– see Partnerships

Party to loan relationships represented by gilts

Payment under, meaning

Payments subject to deduction of tax

Pre-commencement, adjustments in respect of

Pre-trading expenditure

Price of shares calculated by reference to inter-company loan relationship

Profits and gains, bringing amounts into account

Profits exceeding £5 million

Profits or losses, construction of references to

Profits realised on loan notes, appropriation to share premium account

Proper application of provisions to the assignee company

Provision of shares for transfer pricing purposes

Purposes of trade, meaning

Qualifying corporate bonds


Transitional provisions

Qualifying indexed securities

Related transaction, meaning

Release of loan, covenants in loan agreement


Reorganisations, issue of new securities

Disposal at notional carrying value

Fair value accounting


Repairing balance sheet of group company

Repeal of certain provisions relating to late interest etc

Repeal of uncommenced repeal provisions

Repo arrangements

Repo over interest coupons


Rights or liabilities under, meaning

Risk transfer schemes

– see also Risk transfer schemes


Sale and repurchase of gilts, claim for non-trading deficit

Sale and repurchase of securities


Accounted for as liabilities

Beginning/ceasing to be treated as

Guaranteed returns (pre-22 April 2009)

Outstanding third party obligations

Pre-22 April 2009

Transitional rules, commencement of shares as debt legislation

Shares accounted for as liabilities

Becoming or ceasing to be shares

Conditions shares must meet to be a share

Excepted shares


Rights under creditor relationship

Unallowable purpose

Shares with guaranteed returns

Amounts to be brought into account

Ceasing to be treated as


Non-qualifying shares

Outstanding third party obligations

Shari'a compliant financing arrangements

Shari'a law compliant arrangements

Sovereign debts

Stock lending

Stock lending transactions

Structured finance arrangements

– see also Finance arrangements


Substantial modification

Cases where credits not required to be brought into account

Swap agreements, qualifying payments/allocation issue/unallowable purpose issue

Tax avoidance

Connected parties

Control, meaning


Disposals for consideration not fully recognised by accounting practice

European cross-border mergers

European cross-border transfer of business

Exchange gains and losses, transactions not at arm's length

Financial traders, creditors


Insurance companies, creditors

Non-trading deficits

Partnerships, connected parties

Priority rules

Resetting interest rates (reset bonds), fair value accounting

Tax relief schemes, restriction of interest relief

Transactions not at arm's length

Unallowable purposes

Tax mismatch schemes

Economic profits and losses, meaning


Losses and profits to be disregarded



Relevant tax advantage/disadvantage, meaning

Scheme loss/profit, meaning

Scheme period, meaning

Scheme, meaning

Tax capacity assumption

Tax relief

Bad and doubtful debts


Thin capitalisation

Trade, meaning

Transactions for the lending of money, meaning

Transfer of contingent debt asset

Transfer pricing adjustments

Transfer pricing rules applied to issue price of tracker shares

Transitional adjustments relating to loan relationships

Transitional provisions and savings

Transport transfer schemes

Treasury stock 2008–12 not redeemed pre-6 April 2009

Unallowable purpose

Unallowable purposes

Unit trusts

– see also Unit trust schemes


Value of the shares income of the share recipient

Venture capital trusts

Winding up or administration

Worldwide debt cap

Writing-off government investment