Apportionment of (UK and foreign income)

Commentary – Woolley on Financial Planning with Trusts 16.4.2

Authorised unit trust amalgamating/converting to open-ended investment company

Legislation/Regulatory – SI 2006/964 reg. 80

Calculation of taxable rental income

Commentary – Golding and Connolly on Advising British Expats 5.14 ; Golding and Connolly on Living and Working Abroad 6.10.14

Carry forward

Commentary – Ford on Tax Losses 14.2.1Ford on Tax Losses 14.2.3

Companies with investment business

– see Companies with investment business; Company with investment business

Company with investment business, restriction on deduction

Legislation/Regulatory – CTA2010 s. 682, 699

Corporate landlords

Commentary – Chanda on Property Investment 6.8.5

Definition

Commentary – Ford on Tax Losses 14.1

Delisting of shares

Case Law – Dawsongroup Ltd [2009] TC 00105

Excess expenses – current rules

Commentary – Ford on Tax Losses 14.2.3

Excess expenses – former rules (to 31 March 2017)

Commentary – Ford on Tax Losses 14.2.2

Generally

Commentary – Ford on Tax Losses 14.1

Group relief

Commentary – Quick Overview ¶36265 ; Ford on Tax Losses 13.1Ford on Tax Losses 14.2.3
Legislation/Regulatory – CTA2010 s. 103, 105

HMRC guidance

Commentary – Woolley on Financial Planning with Trusts 7.3.4

Insurance companies

– see Insurance companies

Investment companies

– see also Company with investment business; Companies with investment business

Generally

Commentary – Quick Overview ¶23010–Quick Overview ¶23020

Life assurance business, deduction

Case Law – Johnson (HM Inspector of Taxes) v. Prudential Assurance Co Ltd. [1998] BTC 112 ; Johnson (HM Inspector of Taxes) v Prudential Assurance Co Ltd. [1996] BTC 375

Manufactured dividends, paid out of Caymans Islands company share premium account

Case Law – First Nationwide [2010] TC 00339 ; First Nationwide v Revenue and Customs Commissioners. [2011] BTC 1,640 ; Revenue and Customs Commissioners v First Nationwide. [2012] BTC 99

Mineral royalties

Legislation/Regulatory – ITTOIA2005 s. 339

Oil extraction activities

Legislation/Regulatory – CTA2010 s. 303

Relief for

Commentary – Ford on Tax Losses 14.2

Trust income

Commentary – Quick Overview ¶62285

Trustees

Commentary – Quick Overview ¶62205

Trusts with vulnerable beneficiaries

Commentary – Tax Reporter ¶355-450
HMRC Guidance – TSEM3440

Unallowable purpose

Commentary – Ford on Tax Losses 14.1

Unrelieved UK property losses

Commentary – Ford on Tax Losses 14.2.4

Waste disposal landfill site restoration payments

Case Law – Dispit Ltd v. R & C Commrs (2007) Sp C 579