Commentary

D1.220 General principles

Corporate tax
Corporate tax | Commentary

D1.220 General principles

Corporate tax | Commentary

Companies carrying on mutual business or not carrying on a business

D1.220 General principles

Businesses in which the customers and the persons carrying on the business are the same persons, so that any profit made from those persons as customers belongs to the same persons as the traders, are exempt from tax, on the basis of the principle of mutuality1. However, this general position does not apply to transactions, mutual or otherwise, conducted with non-members.

On the question of when mutual trading is or is not assessable, see B1.436–B1.440. The treatment of the 'dividend' of

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